Business deductions and transfer pricing issues: tribunal treatment of software write-offs, donation receipts, warranty provisions, and related expens...
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NCLAT dismissed the appeal, finding the delay of 2659 days in filing the appeal was unjustifiable and beyond the statutorily prescribed 90-day limitation period. The tribunal held that the appellant failed to demonstrate sufficient cause for the extensive delay, noting a lack of diligence in tracking proceedings and missing critical procedural timelines. The application for condonation of delay was rejected, emphasizing the appellant's responsibility to maintain procedural punctuality and timely pursue legal remedies within the prescribed statutory framework.
NCLAT dismissed the appeal, finding the delay of 2659 days in filing the appeal was unjustifiable and beyond the statutorily prescribed 90-day limitation period. The tribunal held that the appellant failed to demonstrate sufficient cause for the extensive delay, noting a lack of diligence in tracking proceedings and missing critical procedural timelines. The application for condonation of delay was rejected, emphasizing the appellant's responsibility to maintain procedural punctuality and timely pursue legal remedies within the prescribed statutory framework.
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