Charitable trust registration requires a specified-violation notice; settled cash deposits and related-party payments did not justify cancellation or ...
External development charges trigger TDS under section 194C, while disputed administrative payments require factual verification and fresh adjudicatio...
Section 270AA penalty immunity requires identified statutory defaults and a hearing before rejection; reassessment disclosure may constitute under-rep...
Section 80JJAA employee-cost deduction allowed for deployed staff but barred against transfer-pricing income enhancement, with pricing issues remanded...
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Negative liens over operating assets can constitute international transactions requiring arm's-length pricing reflecting restricted borrowing and expa...
Cross-examination rights in Customs Broker revocation inquiries require witness examination; procedural denial may be cured through fresh adjudication...
ITAT condoned a 450-day delay in filing an appeal, prioritizing substantial justice over technical procedural constraints. The tribunal determined that the delay was not excessive, referencing precedent cases where much longer delays were excused. The decision emphasized that technical limitations should not prevent judicial review when a reasonable cause exists. The tribunal admitted the appeal for adjudication and granted the assessee an opportunity to represent their case before the Assessing Officer, while simultaneously imposing a cost of Rs. 5,000 as a penalty for procedural laxity. The ruling underscores the principle that justice should prevail over strict procedural adherence, particularly when no deliberate misconduct is evident.
ITAT condoned a 450-day delay in filing an appeal, prioritizing substantial justice over technical procedural constraints. The tribunal determined that the delay was not excessive, referencing precedent cases where much longer delays were excused. The decision emphasized that technical limitations should not prevent judicial review when a reasonable cause exists. The tribunal admitted the appeal for adjudication and granted the assessee an opportunity to represent their case before the Assessing Officer, while simultaneously imposing a cost of Rs. 5,000 as a penalty for procedural laxity. The ruling underscores the principle that justice should prevail over strict procedural adherence, particularly when no deliberate misconduct is evident.
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