Court Allows 460-Day Delay in Appeals on Profit Attribution, Closing Case with No Substantial Legal Questions Found.

The court condoned a 460-day delay in re-filing appeals by the appellant/revenue, allowing the appeals to be decided on their merits. The appeals, concerning Assessment Years 2007-08 to 2014-15, challenged an Income Tax Appellate Tribunal order. The primary issue was the attribution of 15 percent of profits from Indian operations to the respondent/assessee, as previously upheld by the SC. Finding no substantial question of law, the court closed the appeals, with orders to be dispatched to the respondent/assessee through all available modes, including e-mail.

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Issues involved: Applications for condonation of delay in re-filing appeals, Appeals concerning different Assessment Years, Merits of the case based on Supreme Court decision.

Condonaion of Delay: The appellant/revenue filed applications seeking condonation of a 460-day delay in re-filing the appeals. The court, intending to decide the appeals on merits, inclined to condone the delay and ordered accordingly, disposing of the applications.

Assessment Years: The appeals pertained to various Assessment Years - 2007-08, 2008-09, 2009-10, 2010-11, 2011-12, 2012-13, and 2014-15. The appellant/revenue aimed to challenge the common order of the Income Tax Appellate Tribunal dated 13.10.2021.

Merits of the Case: The key issue in the appeals was whether 15 percent of the profits from Indian operations could be attributed to the respondent/assessee, a matter previously upheld by the Supreme Court in a related case. The court found no substantial question of law for consideration based on the previous decisions and closed the appeals accordingly. The order was to be dispatched to the respondent/assessee via all modes, including e-mail.

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