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 HC sustained rejection of a revision application filed with a delay of 1,460 days because the explanation of partner disputes was vague and did not establish sufficient cause. It noted that the firm continued to comply with statutory obligations, including audits and return filing, during the alleged period of impediment, showing no inability to file on time. As the Commissioner's view on unexplained delay was a plausible one, no interference was warranted in writ jurisdiction. The Court also held that, once delay was the ground of rejection, the authority should not have commented on merits; those observations were directed to be ignored and not treated as precedent.
The HC sustained rejection of a revision application filed with a delay of 1,460 days because the explanation of partner disputes was vague and did not establish sufficient cause. It noted that the firm continued to comply with statutory obligations, including audits and return filing, during the alleged period of impediment, showing no inability to file on time. As the Commissioner's view on unexplained delay was a plausible one, no interference was warranted in writ jurisdiction. The Court also held that, once delay was the ground of rejection, the authority should not have commented on merits; those observations were directed to be ignored and not treated as precedent.
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