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 writ petition seeking condonation of delay for filing an appeal under Section 107 of the Act, holding that the statutory limitation is absolute and not extendable by the writ court or by application of Section 5 of the Limitation Act. The court reiterated that the Act constitutes a self-contained code with an inbuilt limitation mechanism, thereby implicitly excluding the Limitation Act's extension power. The appellate forum and the prescribed statutory procedure are the sole remedy for challenge; equitable relief to condone delay beyond the statutory period is unavailable. Accordingly, the petitioner's delay was incurable and the petition was dismissed.
The HC dismissed the writ petition seeking condonation of delay for filing an appeal under Section 107 of the Act, holding that the statutory limitation is absolute and not extendable by the writ court or by application of Section 5 of the Limitation Act. The court reiterated that the Act constitutes a self-contained code with an inbuilt limitation mechanism, thereby implicitly excluding the Limitation Act's extension power. The appellate forum and the prescribed statutory procedure are the sole remedy for challenge; equitable relief to condone delay beyond the statutory period is unavailable. Accordingly, the petitioner's delay was incurable and the petition was dismissed.
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