Composite inpatient healthcare supply may retain exemption despite MRP medicine billing, while separate taxable sale characterisation remains disputed...
Working-capital adjustment determines whether software-services transfer-pricing margins fall within the statutory tolerance range, eliminating any ad...
Permanent establishment deductions upheld for expatriate salaries, direct costs and trading losses, while head-office costs require fresh classificati...
Data transmission equipment classification under CTSH 8517 62 remains distinct from residual classification, with exemption evidence requiring scrutin...
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Delay in filing the appeal against the intimation under section 143(1) was condoned because the assessee had pursued rectification and a reminder, and the time taken in that process was treated as beyond its control. Applying the principle of sufficient cause, the Tribunal held that limitation provisions should be construed liberally to advance substantial justice where there is no negligence, inaction or lack of bona fides. The order dismissing the appeal on limitation was set aside and the matter was restored for decision on merits. The connected appeal against the rectification order was dismissed as infructuous after restoration of the main appeal.
Delay in filing the appeal against the intimation under section 143(1) was condoned because the assessee had pursued rectification and a reminder, and the time taken in that process was treated as beyond its control. Applying the principle of sufficient cause, the Tribunal held that limitation provisions should be construed liberally to advance substantial justice where there is no negligence, inaction or lack of bona fides. The order dismissing the appeal on limitation was set aside and the matter was restored for decision on merits. The connected appeal against the rectification order was dismissed as infructuous after restoration of the main appeal.
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