Allocation of registration charges: contractual clause overriding statutory presumption allowed as deduction against capital gain after unrebutted doc...
Expenditure tied to investments yielding exempt income restricted to attributable costs; broader disallowance disallowed and adjustments to WDV and mi...
Admissibility of Investigative Statements invalidated reliance on coerced emails and valuation redetermination, resulting in set aside of penalties an...
Classification of printed technical documents: specific Chapter 49.01 entry prevails, enabling claimed customs exemptions for imported manuals and rep...
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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