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 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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