Tax exemption for specified legal-services authority income applies retrospectively, subject to non-commercial activity, unchanged income sources, and...
Approved resolution plans extinguish unsubmitted pre-approval tax claims, preventing later recovery outside the insolvency process and preserving a cl...
Transfer pricing comparability requires functional alignment and permits working capital adjustment, while APA margins cannot govern non-covered years...
Treaty benefit, goodwill depreciation and hedging costs: export commission disallowed, while key business deductions and depreciation claims succeeded...
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The High Court considered the maintainability of a review petition based on a subsequent judgment and the condonation of a 619-day delay in filing the civil review petition. The appellant attributed the delay to the Counsel's actions. The main issue was the entitlement of exemption u/s 80-P(2)(a)(i) and the taxability of transfer charges received by the Samiti. The Court referred to a Supreme Court decision regarding the nature of transfer charges. The Court held that a decision based on a question of law, if subsequently reversed or modified by a superior court, does not form grounds for review. The Court noted a split verdict in another Supreme Court case. The Court emphasized that entertaining a review petition ignoring statutory provisions would create uncertainty. Consequently, the appeal for condonation of the delay in filing the civil review petition was dismissed.
The High Court considered the maintainability of a review petition based on a subsequent judgment and the condonation of a 619-day delay in filing the civil review petition. The appellant attributed the delay to the Counsel's actions. The main issue was the entitlement of exemption u/s 80-P(2)(a)(i) and the taxability of transfer charges received by the Samiti. The Court referred to a Supreme Court decision regarding the nature of transfer charges. The Court held that a decision based on a question of law, if subsequently reversed or modified by a superior court, does not form grounds for review. The Court noted a split verdict in another Supreme Court case. The Court emphasized that entertaining a review petition ignoring statutory provisions would create uncertainty. Consequently, the appeal for condonation of the delay in filing the civil review petition was dismissed.
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