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International transaction benchmarking restricts transfer pricing adjustments to associated-enterprise dealings, while functional comparability govern...
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Appeal dismissed due to filing beyond statutory limitation period. Petitioner's registration cancelled earlier, failed to avail amnesty scheme allowing restoration upon clearing dues. Petitioner not registered dealer during intervening period, activities unmonitored, transactions unascertainable. Petitioner did not controvert allegation of non-filing returns for six months. Law favors diligent, not indolent. Delay counted against petitioner. Petition dismissed.
Appeal dismissed due to filing beyond statutory limitation period. Petitioner's registration cancelled earlier, failed to avail amnesty scheme allowing restoration upon clearing dues. Petitioner not registered dealer during intervening period, activities unmonitored, transactions unascertainable. Petitioner did not controvert allegation of non-filing returns for six months. Law favors diligent, not indolent. Delay counted against petitioner. Petition dismissed.
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