Revenue neutrality in domestic related-party loans can require deletion of interest transfer pricing adjustments after domestic-transaction verificati...
Pre-enactment land-sale agreements escape stamp-duty value substitution where substantial banking-channel consideration was received before Section 43...
The HC dismissed the petition challenging the order refusing to entertain an appeal, holding the appeal was instituted beyond the maximum condonable period and no non-communication of the Order-in-Original was established. The court found the reasons for delay insufficient and concluded the appeal exceeded the statutory extended limitation period, precluding further condonation. Exercising jurisdiction under Article 226 could not subvert the legislative scheme embodied in the statutory limitation framework (including the prescribed condonable period), and the petitioner's arguable merits could not cure the jurisdictional bar. Consequently, the petition was dismissed and the impugned order declining to admit the appeal was upheld.
The HC dismissed the petition challenging the order refusing to entertain an appeal, holding the appeal was instituted beyond the maximum condonable period and no non-communication of the Order-in-Original was established. The court found the reasons for delay insufficient and concluded the appeal exceeded the statutory extended limitation period, precluding further condonation. Exercising jurisdiction under Article 226 could not subvert the legislative scheme embodied in the statutory limitation framework (including the prescribed condonable period), and the petitioner's arguable merits could not cure the jurisdictional bar. Consequently, the petition was dismissed and the impugned order declining to admit the appeal was upheld.
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