Appeal allows marketing payments as deductible business expenses under Sec.37; director pay retained; R&D deductible from certificate date under Sec.3...
Registration under s.12AB upheld; CIT(Exemptions) exceeded jurisdiction by deciding taxability instead of preliminary verification and registration di...
Dependent Agent PE unresolved for lack of factual inquiry; arm's-length distribution accepted; royalty claim rejected; 15% refund interest (Section 24...
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Appellant's appeal before ITAT is dismissed for non-admission due to inordinate delay of 2,121 days; condonation of delay is refused for want of "sufficient cause" and bona fides. Tribunal found the appeal was prosecuted to exploit process of law after multiple earlier adjudications (AO, CIT(A), Coordinate Bench) concerning alleged bogus purchases where AO had made limited additions and earlier appellate fora rejected genuineness/identity. The Tribunal held equitable pleas of liberal or justice-oriented approach cannot override statutory limitation; public-policy underpinning of limitation bars revival of stale matters. Consequently, appeal is rejected purely on limitation grounds and is not admitted for adjudication.
Appellant's appeal before ITAT is dismissed for non-admission due to inordinate delay of 2,121 days; condonation of delay is refused for want of "sufficient cause" and bona fides. Tribunal found the appeal was prosecuted to exploit process of law after multiple earlier adjudications (AO, CIT(A), Coordinate Bench) concerning alleged bogus purchases where AO had made limited additions and earlier appellate fora rejected genuineness/identity. The Tribunal held equitable pleas of liberal or justice-oriented approach cannot override statutory limitation; public-policy underpinning of limitation bars revival of stale matters. Consequently, appeal is rejected purely on limitation grounds and is not admitted for adjudication.
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