Transfer pricing comparability requires functional alignment and permits working capital adjustment, while APA margins cannot govern non-covered years...
Treaty benefit, goodwill depreciation and hedging costs: export commission disallowed, while key business deductions and depreciation claims succeeded...
Undisclosed foreign asset classification requires an unexplained source; unrebutted affidavits and corroborative evidence defeated the Black Money Act...
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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