Pre-amendment reassessment limitation bars late notices under the preserved regime, invalidating consequential reassessment for affected earlier asses...
Cash-sales explanations for bank deposits require documentary reconciliation; reassessment notice survived where effective response time was available...
Functional comparability in transfer pricing prevents ad hoc arm's length adjustments where functions, assets, risks and reliable comparables are unes...
Contingency expenses, exempt-income disallowance, and royalty benchmarking: unsupported adjustments were deleted under consistent accounting and trans...
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The HC allowed the applicant's impleadment application and condoned the delay in seeking substitution as legal representative, holding that statutory provisions under FERA and FEMA preserve the right of legal representatives to continue pending proceedings and do not impose a restrictive timeline for substitution. Having regard to the prolonged non-listing of the appeal from 2009 to 2022, the applicant's lack of knowledge of the appeal's pendency until 2023 and the peculiar facts surrounding the deceased-appellant's death, the Court found a bona fide and reasonable explanation for the delay of 3,621 days. The application for condonation is allowed and the applicant is entitled to be substituted as legal representative.
The HC allowed the applicant's impleadment application and condoned the delay in seeking substitution as legal representative, holding that statutory provisions under FERA and FEMA preserve the right of legal representatives to continue pending proceedings and do not impose a restrictive timeline for substitution. Having regard to the prolonged non-listing of the appeal from 2009 to 2022, the applicant's lack of knowledge of the appeal's pendency until 2023 and the peculiar facts surrounding the deceased-appellant's death, the Court found a bona fide and reasonable explanation for the delay of 3,621 days. The application for condonation is allowed and the applicant is entitled to be substituted as legal representative.
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