Pre-amendment reassessment limitation bars late notices under the preserved regime, invalidating consequential reassessment for affected earlier asses...
Cash-sales explanations for bank deposits require documentary reconciliation; reassessment notice survived where effective response time was available...
Functional comparability in transfer pricing prevents ad hoc arm's length adjustments where functions, assets, risks and reliable comparables are unes...
Contingency expenses, exempt-income disallowance, and royalty benchmarking: unsupported adjustments were deleted under consistent accounting and trans...
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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TaxTMI 
TaxTMI 
of 4918 
