Patent-settlement expenditure treated as commercially expedient revenue outlay, with foreign-law restrictions inapplicable before the prospective amen...
International transaction benchmarking restricts transfer pricing adjustments to associated-enterprise dealings, while functional comparability govern...
Joint development agreements defer taxable transfer where possession lacks part performance, while completed flats determine consideration and exempti...
Passenger baggage re-export requires true declaration and cannot be granted indirectly through discretionary redemption of undeclared prohibited goods...
Condonation of delay in customs appeals requires a bona fide, satisfactory explanation covering the entire period of delay. Although "sufficient cause" receives a liberal, justice-oriented construction, that approach does not excuse gross negligence, lack of diligence or prolonged inaction. Participation through counsel, communication of the adjudication order to counsel, departmental efforts to serve the order, and failure to enquire about the outcome for nearly three years may support refusal of condonation; later receipt of an order copy does not explain earlier inaction. Under the Customs Act, High Court review does not permit reappreciation of such factual findings absent perversity, disregard of material evidence or legal error.
Condonation of delay in customs appeals requires a bona fide, satisfactory explanation covering the entire period of delay. Although "sufficient cause" receives a liberal, justice-oriented construction, that approach does not excuse gross negligence, lack of diligence or prolonged inaction. Participation through counsel, communication of the adjudication order to counsel, departmental efforts to serve the order, and failure to enquire about the outcome for nearly three years may support refusal of condonation; later receipt of an order copy does not explain earlier inaction. Under the Customs Act, High Court review does not permit reappreciation of such factual findings absent perversity, disregard of material evidence or legal error.
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