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...
Undisclosed foreign asset classification requires an unexplained source; unrebutted affidavits and corroborative evidence defeated the Black Money Act...
Failure to File Appeal within prescribed period of limitation - The court observed that despite the various grounds raised by the petitioner, the failure to file an appeal within the statutory period or seek condonation of delay rendered the writ petition vulnerable to dismissal. Citing the decision of the Hon'ble Supreme Court in a similar case, the High Court emphasized that the remedy of appeal is a creature of statute. The court highlighted the importance of adhering to statutory timelines for filing appeals and condoning delays only with valid reasons. Consequently, the High Court dismissed the petition.
Failure to File Appeal within prescribed period of limitation - The court observed that despite the various grounds raised by the petitioner, the failure to file an appeal within the statutory period or seek condonation of delay rendered the writ petition vulnerable to dismissal. Citing the decision of the Hon'ble Supreme Court in a similar case, the High Court emphasized that the remedy of appeal is a creature of statute. The court highlighted the importance of adhering to statutory timelines for filing appeals and condoning delays only with valid reasons. Consequently, the High Court dismissed the petition.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4807 
Join Channel 
