Service permanent establishment requires non-auxiliary services, while arm's-length distributor remuneration precludes further profit attribution in I...
Make-available condition excludes standard SaaS subscription receipts where customers receive no independently usable technical knowledge after subscr...
Anonymous donation classification fails where charitable trusts maintain undisputed donor identity records and evidence corpus contributions' intended...
Transfer pricing method selection favours TNMM where medical-equipment distribution involves substantial post-import value addition and operational ri...
Post-export shipping bill conversion remains available where contemporaneous evidence supports EPCG benefits despite curable procedural omissions and ...
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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