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External development charges trigger TDS under section 194C, while disputed administrative payments require factual verification and fresh adjudicatio...
Section 270AA penalty immunity requires identified statutory defaults and a hearing before rejection; reassessment disclosure may constitute under-rep...
Section 80JJAA employee-cost deduction allowed for deployed staff but barred against transfer-pricing income enhancement, with pricing issues remanded...
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Cross-examination rights in Customs Broker revocation inquiries require witness examination; procedural denial may be cured through fresh adjudication...
Condonation of delay in filing appeal before the appellate authority - The Appellate Authority also considered the extension of limitation granted by the Hon'ble Supreme Court due to the pandemic situation, which saved the limitation between 15.03.2020 and 28.02.2022. The Supreme Court directed that appeals could be filed within ninety days from 01.03.2022, which means an appeal could have been filed on or before 29.05.2022. However, the petitioner filed the appeal on 13.04.2023, after 289 days from the expiration of even the extended limitation period. - The High Court dismissed the writ petition.
Condonation of delay in filing appeal before the appellate authority - The Appellate Authority also considered the extension of limitation granted by the Hon'ble Supreme Court due to the pandemic situation, which saved the limitation between 15.03.2020 and 28.02.2022. The Supreme Court directed that appeals could be filed within ninety days from 01.03.2022, which means an appeal could have been filed on or before 29.05.2022. However, the petitioner filed the appeal on 13.04.2023, after 289 days from the expiration of even the extended limitation period. - The High Court dismissed the writ petition.
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