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...
The HC declined to interfere with the Tribunal's refusal to condone a 188-day delay in filing an appeal. The Court recognized its limited supervisory jurisdiction, noting it cannot function as an appellate authority when reviewing such discretionary decisions. The Tribunal's determination regarding insufficient cause for delay showed no illegality or perversity warranting judicial intervention. The Court rejected the petitioner's misplaced reliance on CPC provisions and emphasized that the appropriate remedy was filing an appeal under Section 15Z of SEBI Act, 1992, rather than pursuing a writ petition. Finding no violation of natural justice or statutory requirements, the HC dismissed the petition as lacking merit.
The HC declined to interfere with the Tribunal's refusal to condone a 188-day delay in filing an appeal. The Court recognized its limited supervisory jurisdiction, noting it cannot function as an appellate authority when reviewing such discretionary decisions. The Tribunal's determination regarding insufficient cause for delay showed no illegality or perversity warranting judicial intervention. The Court rejected the petitioner's misplaced reliance on CPC provisions and emphasized that the appropriate remedy was filing an appeal under Section 15Z of SEBI Act, 1992, rather than pursuing a writ petition. Finding no violation of natural justice or statutory requirements, the HC dismissed the petition as lacking merit.
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