Patent-settlement expenditure treated as commercially expedient revenue outlay, with foreign-law restrictions inapplicable before the prospective amen...
International transaction benchmarking restricts transfer pricing adjustments to associated-enterprise dealings, while functional comparability govern...
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CESTAT dismissed the appellant's condonation of delay application for appeals. Despite being a large corporate entity with established legal infrastructure, the appellant failed to provide sufficiently substantive reasons for delay. The tribunal found the explanations vague and unconvincing, including references to cyclone impact and advocate unavailability. Settled legal principles require detailed day-wise explanations for delay, which were absent in this case. The court emphasized that negligence, gross inaction, and lack of bona fides cannot justify time-barred appeals. Consequently, the application was rejected, reinforcing that condonation of delay is not a mere procedural formality but requires compelling and reasonable justifications for each day's postponement.
CESTAT dismissed the appellant's condonation of delay application for appeals. Despite being a large corporate entity with established legal infrastructure, the appellant failed to provide sufficiently substantive reasons for delay. The tribunal found the explanations vague and unconvincing, including references to cyclone impact and advocate unavailability. Settled legal principles require detailed day-wise explanations for delay, which were absent in this case. The court emphasized that negligence, gross inaction, and lack of bona fides cannot justify time-barred appeals. Consequently, the application was rejected, reinforcing that condonation of delay is not a mere procedural formality but requires compelling and reasonable justifications for each day's postponement.
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