Patent-settlement expenditure treated as commercially expedient revenue outlay, with foreign-law restrictions inapplicable before the prospective amen...
International transaction benchmarking restricts transfer pricing adjustments to associated-enterprise dealings, while functional comparability govern...
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Condonation of delay in filing appeal - rejection of appeal on the ground of time bar - Heavy burden lies on such appellant to explain the delay sufficiently, for each day. The explanation on ground of illness, given by appellant is held to be absolutely vague in the present case as the appellant could not substantiate with any medical record. Hence, possibility of appeal filed before Commissioner (Appeals) to be an afterthought and a time gaining strategy cannot be ruled out. - AT
Condonation of delay in filing appeal - rejection of appeal on the ground of time bar - Heavy burden lies on such appellant to explain the delay sufficiently, for each day. The explanation on ground of illness, given by appellant is held to be absolutely vague in the present case as the appellant could not substantiate with any medical record. Hence, possibility of appeal filed before Commissioner (Appeals) to be an afterthought and a time gaining strategy cannot be ruled out. - AT
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