Working-capital adjustment determines whether software-services transfer-pricing margins fall within the statutory tolerance range, eliminating any ad...
Permanent establishment deductions upheld for expatriate salaries, direct costs and trading losses, while head-office costs require fresh classificati...
Data transmission equipment classification under CTSH 8517 62 remains distinct from residual classification, with exemption evidence requiring scrutin...
Condonation of delay - delay of 280 days - sufficient cause - The Tribunal noted that the delay was due to the callous and lackadaisical approach of the appellant in not preferring the appeal within the stipulated time period. - Referring to legal precedents, the Tribunal emphasized the importance of a bona fide explanation for condonation of delay and strict adherence to the law of limitation. - Despite the liberal construction of the term "sufficient cause," the Tribunal found no plausible explanation from the appellant justifying the substantial delay in filing the appeal.
Condonation of delay - delay of 280 days - sufficient cause - The Tribunal noted that the delay was due to the callous and lackadaisical approach of the appellant in not preferring the appeal within the stipulated time period. - Referring to legal precedents, the Tribunal emphasized the importance of a bona fide explanation for condonation of delay and strict adherence to the law of limitation. - Despite the liberal construction of the term "sufficient cause," the Tribunal found no plausible explanation from the appellant justifying the substantial delay in filing the appeal.
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