Working-capital adjustment determines whether software-services transfer-pricing margins fall within the statutory tolerance range, eliminating any ad...
Permanent establishment deductions upheld for expatriate salaries, direct costs and trading losses, while head-office costs require fresh classificati...
Data transmission equipment classification under CTSH 8517 62 remains distinct from residual classification, with exemption evidence requiring scrutin...
HC condoned delay in filing appeal by small partnership firm, setting aside appellate authority's rejection. Court found appellate authority erroneously limited condonation to one-month period beyond prescribed time, contradicting precedent in S.K. Chakraborty case. Considering petitioner's bona fide intent and absence of deliberate delay, HC directed appellate authority to hear appeal on merits within eight weeks. Court emphasized appellate authority's failure to properly exercise jurisdiction in mechanically rejecting appeal on limitation grounds without adequately considering explanation for delay. Appeal to be heard after giving petitioners opportunity of hearing.
HC condoned delay in filing appeal by small partnership firm, setting aside appellate authority's rejection. Court found appellate authority erroneously limited condonation to one-month period beyond prescribed time, contradicting precedent in S.K. Chakraborty case. Considering petitioner's bona fide intent and absence of deliberate delay, HC directed appellate authority to hear appeal on merits within eight weeks. Court emphasized appellate authority's failure to properly exercise jurisdiction in mechanically rejecting appeal on limitation grounds without adequately considering explanation for delay. Appeal to be heard after giving petitioners opportunity of hearing.
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