Transfer pricing comparables and operating income principles applied to software development services, with exclusions, inclusions, and tax credit ver...
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The HC set aside the impugned order rejecting the appeal as time-barred by 23 days and remitted the matter to the appellate authority for fresh adjudication within a reasonable time. The court found the appellate authority erred in adopting a hyper-technical approach where the appellant, owing to bona fide confusion and portal/upload irregularities (including non-upload of the order summary and issuance of appeal number on physical filing), could not be deemed to have wilfully delayed filing; medical infirmity of the appellant was noted. The HC directed the appellate authority to entertain the appeal in accordance with Rule 108(3) provisos and applicable law and to decide afresh.
The HC set aside the impugned order rejecting the appeal as time-barred by 23 days and remitted the matter to the appellate authority for fresh adjudication within a reasonable time. The court found the appellate authority erred in adopting a hyper-technical approach where the appellant, owing to bona fide confusion and portal/upload irregularities (including non-upload of the order summary and issuance of appeal number on physical filing), could not be deemed to have wilfully delayed filing; medical infirmity of the appellant was noted. The HC directed the appellate authority to entertain the appeal in accordance with Rule 108(3) provisos and applicable law and to decide afresh.
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