Transfer pricing comparables and operating income principles applied to software development services, with exclusions, inclusions, and tax credit ver...
Transfer pricing on performance guarantees and overdue receivables deleted where warranty obligations were embedded and working capital adjustment alr...
A High Court applied a pragmatic approach to condonation of delay and held that a one-day delay should not be rejected pedantically where refusal would defeat adjudication on merits. Relying on the principle that substantial justice should prevail over technicalities in limitation matters, and noting the respondent's no-objection, the Court set aside the order treating the appeal as time-barred. The appeal was restored for fresh hearing and decision on merits, while all other contentions, including the underlying tax challenge and impugned notifications, were left open.
A High Court applied a pragmatic approach to condonation of delay and held that a one-day delay should not be rejected pedantically where refusal would defeat adjudication on merits. Relying on the principle that substantial justice should prevail over technicalities in limitation matters, and noting the respondent's no-objection, the Court set aside the order treating the appeal as time-barred. The appeal was restored for fresh hearing and decision on merits, while all other contentions, including the underlying tax challenge and impugned notifications, were left open.
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