Transfer pricing comparability: one support-services company accepted, government-owned and facility-management comparables excluded, forex loss claim...
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Section 107(4) permits a discretionary additional thirty days beyond the primary ninety-day limitation if the appellant shows sufficient cause, and that discretionary period is exhaustive; courts constitutional writ jurisdiction cannot be used to further extend the statutory timeline beyond the total 120 days. Reasons not meeting the sufficient cause standard will not support condonation. Where an alternative efficacious remedy in the statute has been availed, the validity of the original demand order cannot be re-opened via a collateral constitutional challenge. Taxing statutes operate within strict time frames, placing a duty on taxpayers to monitor proceedings and verify orders on the portal.
Section 107(4) permits a discretionary additional thirty days beyond the primary ninety-day limitation if the appellant shows sufficient cause, and that discretionary period is exhaustive; courts constitutional writ jurisdiction cannot be used to further extend the statutory timeline beyond the total 120 days. Reasons not meeting the sufficient cause standard will not support condonation. Where an alternative efficacious remedy in the statute has been availed, the validity of the original demand order cannot be re-opened via a collateral constitutional challenge. Taxing statutes operate within strict time frames, placing a duty on taxpayers to monitor proceedings and verify orders on the portal.
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