Head Office cost allocation requires prescribed transfer-pricing methods; treaty ceilings bar surcharge and cess, while duplicate taxation is excluded...
Cost-to-cost reimbursement of seconded employees is not service consideration; transfer-pricing markup was deleted and amalgamation amortisation allow...
Crystallisation of liability supports prior-period expense deduction, while functionally distinct divisions require separate transfer-pricing benchmar...
Functional comparability under TNMM requires transaction-specific FAR analysis before benchmarking business-support services provided to associated en...
Advance pricing agreement methodology can guide benchmarking for non-covered years when functions, assets, risks and activities remain materially unch...
Tax-audit exemption for substantially State-funded educational universities prevents audit-failure penalties where income qualifies for statutory exem...
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Limitation for an appeal under the Insolvency and Bankruptcy Code against an NCLAT order runs from pronouncement of the order. The prescribed 45-day period, with a maximum 15-day condonable extension, establishes an absolute 60-day limit. Section 12(2) of the Limitation Act excludes only the time from applying for a certified copy until it becomes available; delay in applying remains countable. Obtaining a copy cannot defer limitation, and delay beyond the outer limit cannot be condoned.
Limitation for an appeal under the Insolvency and Bankruptcy Code against an NCLAT order runs from pronouncement of the order. The prescribed 45-day period, with a maximum 15-day condonable extension, establishes an absolute 60-day limit. Section 12(2) of the Limitation Act excludes only the time from applying for a certified copy until it becomes available; delay in applying remains countable. Obtaining a copy cannot defer limitation, and delay beyond the outer limit cannot be condoned.
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