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Priority of set-off: brought forward business losses must be adjusted before unabsorbed depreciation; procedural safeguards required for invoking rest...
Condonation of delay was refused where the appellant failed to...
Condonation of Delay denied: communication lapses and corporate restructuring found insufficient; prolonged inaction and lack of bona fides led to refusal.
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Condonation of delay was refused where the appellant failed to establish sufficient cause for an unexplained 802 day delay. The tribunal found the asserted non intimation contradicted contemporaneous affidavits confirming receipt of orders and therefore was not a valid ground. The claimed corporate restructuring was held vague, factually belied by completion before the impugned orders and inadequate given the appellant's institutional capacity and awareness of the time value of money. The appellant's prolonged inaction and lack of vigilance, together with absence of bona fide supporting material, resulted in denial of condonation under limitation principles by the ITAT.
Condonation of delay was refused where the appellant failed to establish sufficient cause for an unexplained 802 day delay. The tribunal found the asserted non intimation contradicted contemporaneous affidavits confirming receipt of orders and therefore was not a valid ground. The claimed corporate restructuring was held vague, factually belied by completion before the impugned orders and inadequate given the appellant's institutional capacity and awareness of the time value of money. The appellant's prolonged inaction and lack of vigilance, together with absence of bona fide supporting material, resulted in denial of condonation under limitation principles by the ITAT.
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