Charitable trust registration requires a specified-violation notice; settled cash deposits and related-party payments did not justify cancellation or ...
External development charges trigger TDS under section 194C, while disputed administrative payments require factual verification and fresh adjudicatio...
Section 270AA penalty immunity requires identified statutory defaults and a hearing before rejection; reassessment disclosure may constitute under-rep...
Section 80JJAA employee-cost deduction allowed for deployed staff but barred against transfer-pricing income enhancement, with pricing issues remanded...
Transfer-pricing methodology protects commercially genuine associated-enterprise payments, while pre-2016 secondary adjustments and related notional i...
Negative liens over operating assets can constitute international transactions requiring arm's-length pricing reflecting restricted borrowing and expa...
Cross-examination rights in Customs Broker revocation inquiries require witness examination; procedural denial may be cured through fresh adjudication...
The ITAT dismissed the application for condonation of delay of 1,370 days, holding that the appellant failed to establish "sufficient cause" for the delay and did not demonstrate requisite due diligence in prosecuting the appeal. The Tribunal emphasized that the burden rests on the appellant to explain delay and that authorities are not obliged to investigate causes. Reliance on erroneous advice of a tax consultant, without contemporaneous steps or plausible justification, did not absolve the appellant-a private limited company-of statutory obligations; although no mala fides were found, the delay was substantial and unjustified, and the appeal was barred by lapse of time.
The ITAT dismissed the application for condonation of delay of 1,370 days, holding that the appellant failed to establish "sufficient cause" for the delay and did not demonstrate requisite due diligence in prosecuting the appeal. The Tribunal emphasized that the burden rests on the appellant to explain delay and that authorities are not obliged to investigate causes. Reliance on erroneous advice of a tax consultant, without contemporaneous steps or plausible justification, did not absolve the appellant-a private limited company-of statutory obligations; although no mala fides were found, the delay was substantial and unjustified, and the appeal was barred by lapse of time.
Note: It is a system-generated summary and is for quick reference only.