Departmental appeal limitation after call-book recall preserves original filing, while documented correlation supports SAD refund on imported granules...
Income-tax prosecution fails when appellate remand removes its factual foundation; directors require company arraignment for vicarious criminal liabil...
Capital character of assignment consideration prevents taxation as residuary income, while unsupported interest-related expenditure remains non-deduct...
Make-available condition shields regional support-service receipts from Indian taxation where no independent capability or permanent establishment exi...
Transfer-pricing treatment of corporate guarantees and convertible loans followed prior-year consistency, with taxable foreign dividends excluded from...
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.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
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