Permanent-establishment reassessment cannot revisit scrutinised disclosures; extended reopening fails without undisclosed material facts and within st...
Modified returns after business reorganisation must be assessed within pending proceedings, barring parallel scrutiny and consequential transfer prici...
Turnover mismatches under percentage-completion accounting cannot alone establish suppressed income where customer advances remain recorded as liabili...
Section 260A(2A) of the Income Tax Act does not expressly exclude application of the Limitation Act, declare the High Court functus officio after expiry of the appeal period, or contain restrictive wording barring condonation. Departmental processing, approval, preparation and execution of the appeal memorandum collectively established sufficient cause and bona fide diligence for a short delay. Merits of the proposed appeal should not be examined while deciding limitation, as that would compromise fairness at the admission stage. The delay was condoned, and the income-tax appeal was directed to be registered and listed for admission.
Section 260A(2A) of the Income Tax Act does not expressly exclude application of the Limitation Act, declare the High Court functus officio after expiry of the appeal period, or contain restrictive wording barring condonation. Departmental processing, approval, preparation and execution of the appeal memorandum collectively established sufficient cause and bona fide diligence for a short delay. Merits of the proposed appeal should not be examined while deciding limitation, as that would compromise fairness at the admission stage. The delay was condoned, and the income-tax appeal was directed to be registered and listed for admission.
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TaxTMI 
TaxTMI 
of 4891 
