Co-operative credit society deduction on bank deposit interest upheld where funds were business funds and income remained attributable to member credi...
Transfer pricing benchmarking and receivables adjustments remanded: segmental financials need proper scrutiny, and foreign-currency interest must trac...
The article addresses limitation on rectification petitions under the statutory four year bar, reasoning that prolonged inaction (nine years) evidences negligence and lack of bona fides and therefore no sufficient cause exists to permit amendment; the earlier authority's dismissal on that ground is endorsed. It separately notes that a short procedural delay in instituting appeals before the Tribunal (12 days) was condoned, but emphasizes that such condonation does not cure the longer statutory bar to rectification, resulting in dismissal of the appeals affected by the inordinate delay.
The article addresses limitation on rectification petitions under the statutory four year bar, reasoning that prolonged inaction (nine years) evidences negligence and lack of bona fides and therefore no sufficient cause exists to permit amendment; the earlier authority's dismissal on that ground is endorsed. It separately notes that a short procedural delay in instituting appeals before the Tribunal (12 days) was condoned, but emphasizes that such condonation does not cure the longer statutory bar to rectification, resulting in dismissal of the appeals affected by the inordinate delay.
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