Supervisory permanent establishment requires project-wise duration and qualifying construction nexus; offshore supplies and salary reimbursements rema...
Transfer-pricing comparability permits fresh objections and filters where software service comparables are functionally unsuitable for arm's-length pr...
Territorial rendering requirement excludes China-based management and consultancy services from fees for technical services under the India-China DTAA...
Condonation of delay in filing the appeal before the CIT(A) - delay of 636 days - The conduct of the assessee is such that there was clear negligence on its part and there is no equitable ground or substantial cause for condoning the delay of 636 days in filing the appeal before the CIT(A). Therefore, we are of the view that the CIT(A) is correctly dismissed the appeal in limine, without condoning the delay of 636 days in filing the appeal before him. - AT
Condonation of delay in filing the appeal before the CIT(A) - delay of 636 days - The conduct of the assessee is such that there was clear negligence on its part and there is no equitable ground or substantial cause for condoning the delay of 636 days in filing the appeal before the CIT(A). Therefore, we are of the view that the CIT(A) is correctly dismissed the appeal in limine, without condoning the delay of 636 days in filing the appeal before him. - AT
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4886 
