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...
Condonation of delay in the Revenue's income-tax appeal depends on whether sufficient cause is shown through a bona fide and adequately explained process, rather than on the length of delay alone. Departmental scrutiny, approvals, record collection and preparation of the appeal memorandum may constitute sufficient cause where the explanation is not specifically denied or shown to be non-existent. Handwritten dates in an otherwise standard-form delay application do not by themselves establish that the explanation is stereotyped or unreliable when the application materially accounts for the delay. On these facts, the departmental procedural delay was treated as bona fide, the delay was condoned, and the appeal was directed for admission processing.
Condonation of delay in the Revenue's income-tax appeal depends on whether sufficient cause is shown through a bona fide and adequately explained process, rather than on the length of delay alone. Departmental scrutiny, approvals, record collection and preparation of the appeal memorandum may constitute sufficient cause where the explanation is not specifically denied or shown to be non-existent. Handwritten dates in an otherwise standard-form delay application do not by themselves establish that the explanation is stereotyped or unreliable when the application materially accounts for the delay. On these facts, the departmental procedural delay was treated as bona fide, the delay was condoned, and the appeal was directed for admission processing.
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