Transfer-pricing treatment of ITeS margins excludes pass-through tax recoveries and separate delayed-receivables interest after working-capital adjust...
Capacity-utilisation adjustments under TNMM can neutralise substantiated COVID-related idle costs where underutilisation materially affects profitabil...
TNMM functional comparability requires excluding rice manufacturers from a pure Basmati rice trader's benchmark and recognising operating export recei...
Working-capital adjustment subsumes delayed-receivable effects in TNMM benchmarking of captive software-development services, avoiding separate notion...
Transfer-pricing comparability requires exclusion of financially illogical super-profit comparables and correction of unsupported annual-report and ma...
Charitable character assessment preserves Section 80G approval despite inclusive spiritual teachings and incidental religious expenditure within the s...
Penalty proceedings for cash-loan acceptance require assessment proceedings and recorded Assessing Officer satisfaction; absent these, the proceedings...
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The High Court considered a Civil Miscellaneous Petition seeking condonation of a delay of 891 days in filing an appeal. Emphasizing the legal maxim "interest reipublicae ut sit finis litium," the Court noted that rules of limitation aim to preserve legal remedies within a legislatively fixed period. Lack of bona fide motive, inaction, and negligence are crucial factors in delay condonation. Referring to a Supreme Court case, the Court highlighted that merely establishing sufficient cause does not automatically entitle a party to condone delay. The term "sufficient cause" was interpreted to require absence of negligence or lack of bona fide intent. Ultimately, the Court found no adequate reason to justify the lengthy delay and dismissed the condonation application.
The High Court considered a Civil Miscellaneous Petition seeking condonation of a delay of 891 days in filing an appeal. Emphasizing the legal maxim "interest reipublicae ut sit finis litium," the Court noted that rules of limitation aim to preserve legal remedies within a legislatively fixed period. Lack of bona fide motive, inaction, and negligence are crucial factors in delay condonation. Referring to a Supreme Court case, the Court highlighted that merely establishing sufficient cause does not automatically entitle a party to condone delay. The term "sufficient cause" was interpreted to require absence of negligence or lack of bona fide intent. Ultimately, the Court found no adequate reason to justify the lengthy delay and dismissed the condonation application.
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