Working-capital adjustment determines whether software-services transfer-pricing margins fall within the statutory tolerance range, eliminating any ad...
Permanent establishment deductions upheld for expatriate salaries, direct costs and trading losses, while head-office costs require fresh classificati...
Data transmission equipment classification under CTSH 8517 62 remains distinct from residual classification, with exemption evidence requiring scrutin...
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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