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...
Governmental authority status supports construction-service exemption, while pre-cutoff contract and stamp-duty compliance requires verification on re...
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The dominant issue was whether delay in filing the return could be condoned under section 119(2)(b) on the ground of "genuine hardship." The Court held that ignorance of tax law is no excuse, and the plea of illiteracy did not establish reasonable cause, particularly since the assessee had timely filed the return for an earlier assessment year, indicating awareness of the filing process. Relying on the principle that statutory time limits must be adhered to and extension is not a vested right, the Court found no perversity in the authority's refusal to condone delay and dismissed the writ petition. - HC
The dominant issue was whether delay in filing the return could be condoned under section 119(2)(b) on the ground of "genuine hardship." The Court held that ignorance of tax law is no excuse, and the plea of illiteracy did not establish reasonable cause, particularly since the assessee had timely filed the return for an earlier assessment year, indicating awareness of the filing process. Relying on the principle that statutory time limits must be adhered to and extension is not a vested right, the Court found no perversity in the authority's refusal to condone delay and dismissed the writ petition. - HC
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