Inaccurate-particulars penalties fail where transfer-pricing documentation shows good faith and due diligence, and underlying capital-gains additions ...
Transfer-pricing tolerance for software sub-licensing falls within the services range, eliminating the adjustment and requiring TDS-credit verificatio...
Customs Broker due diligence requires prescribed KYC, not detecting misdeclarations discoverable only through physical examination, defeating licence ...
E-filing system failure permits exclusion of affected time in insolvency appeals, preventing tribunal technology defects from defeating timely filings...
Pre-existing disputes over outcome-based professional fees can bar Section 9 insolvency proceedings where contractual entitlement requires investigati...
Corresponding scheduled offences preserve money-laundering jurisdiction despite repeal of the central corruption provision where conduct remains cover...
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Section 260-A permits a High Court appeal only where a substantial question of law arises; it does not allow reappreciation of evidence or replacement of concurrent factual findings. Concurrent findings that road and infrastructure works qualified the assessee as a developer eligible for deduction under section 80-IA(4) were based on the record, with no perversity or erroneous legal test shown. Reliance on a previously confirmed Tribunal order and dismissal of a similar appeal for another assessment year did not create a substantial question of law. The Department's appeal was dismissed.
Section 260-A permits a High Court appeal only where a substantial question of law arises; it does not allow reappreciation of evidence or replacement of concurrent factual findings. Concurrent findings that road and infrastructure works qualified the assessee as a developer eligible for deduction under section 80-IA(4) were based on the record, with no perversity or erroneous legal test shown. Reliance on a previously confirmed Tribunal order and dismissal of a similar appeal for another assessment year did not create a substantial question of law. The Department's appeal was dismissed.
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