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...
Condonation of 68 days' delay in filing appeal was denied due to lack of sufficient cause. The appellant failed to demonstrate how he was prevented from filing the appeal within the statutory period u/s 421(3) proviso. The court held that even after showing sufficient cause, parties are not entitled to condonation of delay as a matter of right; the court must exercise discretion. The appellant was clearly negligent, being aware of the order before the deadline, and had already pleaded for extension without prejudice to filing an appeal, indicating awareness of the right to appeal. The court found no sufficient cause preventing the appellant from filing within the extended period and dismissed the delay condonation application.
Condonation of 68 days' delay in filing appeal was denied due to lack of sufficient cause. The appellant failed to demonstrate how he was prevented from filing the appeal within the statutory period u/s 421(3) proviso. The court held that even after showing sufficient cause, parties are not entitled to condonation of delay as a matter of right; the court must exercise discretion. The appellant was clearly negligent, being aware of the order before the deadline, and had already pleaded for extension without prejudice to filing an appeal, indicating awareness of the right to appeal. The court found no sufficient cause preventing the appellant from filing within the extended period and dismissed the delay condonation application.
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