Approved resolution plans extinguish unsubmitted pre-approval tax claims, preventing later recovery outside the insolvency process and preserving a cl...
Transfer pricing comparability requires functional alignment and permits working capital adjustment, while APA margins cannot govern non-covered years...
Treaty benefit, goodwill depreciation and hedging costs: export commission disallowed, while key business deductions and depreciation claims succeeded...
Condonation of delay of 1085 days in filing the appeal u/s 260-A - Revenue's appeal - The court found that the appellant failed to provide a valid explanation for the delay of 1085 days in filing the appeal. Despite the previous appeal being declared infructuous, the court held that it had no relevance to the current appeal, as they pertained to different orders. The court cited a precedent to emphasize that negligence in prosecuting the matter cannot be condoned merely because the government is a party. It highlighted the need for plausible and acceptable explanations for delays.
Condonation of delay of 1085 days in filing the appeal u/s 260-A - Revenue's appeal - The court found that the appellant failed to provide a valid explanation for the delay of 1085 days in filing the appeal. Despite the previous appeal being declared infructuous, the court held that it had no relevance to the current appeal, as they pertained to different orders. The court cited a precedent to emphasize that negligence in prosecuting the matter cannot be condoned merely because the government is a party. It highlighted the need for plausible and acceptable explanations for delays.
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