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...
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.
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