Contingency expenses, exempt-income disallowance, and royalty benchmarking: unsupported adjustments were deleted under consistent accounting and trans...
Disciplinary proportionality requires penalties for Authorised Representative misconduct to match proven harm, leading to reconsideration of registrat...
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.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4918 
