Transfer pricing comparables and adjustments: Tribunal revisits loss-maker status, segmental comparability, working capital relief, and risk allocatio...
Business expenditure disallowance failed where commission, related-party salary and promotion payments were supported by records and inquiry was inade...
Delay in filing the appeal before the Securities Appellate Tribunal was condoned because the appellant showed personal and financial difficulties, family obligations, the father's medical condition, Covid-19 related financial disruption, and a change of address affecting receipt of the impugned order. The decisive consideration was that the forum provides a first appeal on facts and law, and that appellate remedy is a valuable right. The Court therefore condoned the delay subject to costs, set aside the refusal to condone, and restored the appeal for decision on merits without examining the substantive dispute.
Delay in filing the appeal before the Securities Appellate Tribunal was condoned because the appellant showed personal and financial difficulties, family obligations, the father's medical condition, Covid-19 related financial disruption, and a change of address affecting receipt of the impugned order. The decisive consideration was that the forum provides a first appeal on facts and law, and that appellate remedy is a valuable right. The Court therefore condoned the delay subject to costs, set aside the refusal to condone, and restored the appeal for decision on merits without examining the substantive dispute.
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