Patent-settlement expenditure treated as commercially expedient revenue outlay, with foreign-law restrictions inapplicable before the prospective amen...
International transaction benchmarking restricts transfer pricing adjustments to associated-enterprise dealings, while functional comparability govern...
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The ITAT considered the condonation of delay in filing appeals before the CIT(A). The delay of 93 days was attributed to pursuing alternative remedies in the High Court. The ITAT held that the delay was reasonable and not willful, supported by legal precedent. The ITAT emphasized that the cause for delay is crucial, not just the duration. Citing a case where a 21-year delay was condoned, the ITAT found the 93-day delay acceptable. The delay was condoned u/s 253(5) of the Act. Regarding ex-parte assessment orders, the ITAT referred to a High Court decision criticizing the AO's failure to consider the assessee's submissions. The matter was remitted back to the AO for reconsideration, emphasizing adherence to principles of natural justice.
The ITAT considered the condonation of delay in filing appeals before the CIT(A). The delay of 93 days was attributed to pursuing alternative remedies in the High Court. The ITAT held that the delay was reasonable and not willful, supported by legal precedent. The ITAT emphasized that the cause for delay is crucial, not just the duration. Citing a case where a 21-year delay was condoned, the ITAT found the 93-day delay acceptable. The delay was condoned u/s 253(5) of the Act. Regarding ex-parte assessment orders, the ITAT referred to a High Court decision criticizing the AO's failure to consider the assessee's submissions. The matter was remitted back to the AO for reconsideration, emphasizing adherence to principles of natural justice.
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