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Transfer pricing rules require benchmarking corporate guarantees and associated-enterprise advances, while invalid domestic-transaction adjustments ca...
Prospective sugar export prohibition required registered letters of credit; private contracts and export quotas created no enforceable continuation ri...
Retroactive interim-moratorium exclusion permits protective asset disclosure and preservation measures against personal guarantors pending arbitration...
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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