TNMM comparability using audited accounts and working-capital adjustments can eliminate unwarranted transfer-pricing additions where verified margins ...
Gross-profit additions on disputed purchases require reasoned appellate determination; disclosed claims alone do not support inaccurate-particulars pe...
Limitation after transfer-pricing remand: fresh TPO reference did not extend the assessment deadline, rendering the consequential assessment time-barr...
Interim judicial restraint on tax deduction prevents default, while supporting reasonable cause and penalty deletion for foreign-leg LFC reimbursement...
Palmolein classification defeated the crude-oil concession; material misdeclaration sustained recovery and confiscation, while separate false-document...
Section 5 of the Limitation Act, 1963 may apply to special-law appeals through Section 29(2) unless the governing enactment excludes it expressly or by necessary implication. A special limitation period alone is insufficient; exclusion may arise from phrases such as "but not thereafter" or "not exceeding", a defined condonable ceiling, or a self-contained scheme that selectively confers condonation. For appeals under Section 9 of the Chhattisgarh Rajya Suraksha Adhiniyam, the 30-day period and certified-copy exclusion do not bar Section 5 because no outer limit or equivalent restrictive language exists. Delay remains condonable only upon sufficient cause, while applicability before non-court statutory forums depends on the forum and enactment.
Section 5 of the Limitation Act, 1963 may apply to special-law appeals through Section 29(2) unless the governing enactment excludes it expressly or by necessary implication. A special limitation period alone is insufficient; exclusion may arise from phrases such as "but not thereafter" or "not exceeding", a defined condonable ceiling, or a self-contained scheme that selectively confers condonation. For appeals under Section 9 of the Chhattisgarh Rajya Suraksha Adhiniyam, the 30-day period and certified-copy exclusion do not bar Section 5 because no outer limit or equivalent restrictive language exists. Delay remains condonable only upon sufficient cause, while applicability before non-court statutory forums depends on the forum and enactment.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4918 
