Pre-amendment reassessment limitation bars late notices under the preserved regime, invalidating consequential reassessment for affected earlier asses...
Cash-sales explanations for bank deposits require documentary reconciliation; reassessment notice survived where effective response time was available...
Functional comparability in transfer pricing prevents ad hoc arm's length adjustments where functions, assets, risks and reliable comparables are unes...
Contingency expenses, exempt-income disallowance, and royalty benchmarking: unsupported adjustments were deleted under consistent accounting and trans...
Insolvency and BankruptcyAugust 10, 2024Case LawsAT
Condonation of delay in filing the appeal was denied as the appellant failed to fulfill the prerequisites for invoking Section 14 of the Limitation Act. The court held that the appellant was guilty of negligence, lapse, or inaction, and there was no jurisdictional defect or similar cause for the failure of the prior proceeding. The judgment in State Bank of India vs. Visa Steel Ltd. regarding excluding time spent in prosecuting legal remedies while computing limitation u/s 61(2) was distinguished as inapplicable to the present case. Consequently, the period from 08.06.2023 to 03.01.2024 could not be excluded, resulting in a delay of 209 days, exceeding the condonable period of 15 days. The appeal was dismissed due to the inordinate delay.
Condonation of delay in filing the appeal was denied as the appellant failed to fulfill the prerequisites for invoking Section 14 of the Limitation Act. The court held that the appellant was guilty of negligence, lapse, or inaction, and there was no jurisdictional defect or similar cause for the failure of the prior proceeding. The judgment in State Bank of India vs. Visa Steel Ltd. regarding excluding time spent in prosecuting legal remedies while computing limitation u/s 61(2) was distinguished as inapplicable to the present case. Consequently, the period from 08.06.2023 to 03.01.2024 could not be excluded, resulting in a delay of 209 days, exceeding the condonable period of 15 days. The appeal was dismissed due to the inordinate delay.
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