Transfer pricing margin adjustments require matching treatment of non-operating income and related costs, with comparability issues reconsidered on ev...
Preliminary-expense amortisation and MAT exempt-income adjustments prevailed, while trademark costs and managerial remuneration require fresh verifica...
Export valuation requires contemporaneous evidence; unrelated invoices cannot prove overvaluation, and dual penalties on firm and partner are impermis...
Ratification of resignation acceptance validates separation retrospectively, while withdrawal may be refused through reasoned administrative discretio...
Nature-dependent electricity contracts receive new Ind AS accounting, hedge designation, transition and financial-statement disclosure requirements fr...
Alternative GST remedy permitted protective writ intervention for ex parte adjudication, preserving independent appellate review of input tax credit d...
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Inordinate delay in filing the first appeal was not condoned because the assessee failed to show sufficient or bona fide cause. The Tribunal found that the explanation of being unaware of the ex parte assessment was unconvincing, noting the failure to file a return even after notice under section 148 and the non-participation in assessment proceedings, which showed negligence and a lackadaisical approach. Applying the principle that sufficient cause does not extend to inaction, negligence or absence of bona fides, it upheld the CIT(A)'s refusal to exercise discretion under section 249(3) and sustained dismissal of the appeal as time-barred.
Inordinate delay in filing the first appeal was not condoned because the assessee failed to show sufficient or bona fide cause. The Tribunal found that the explanation of being unaware of the ex parte assessment was unconvincing, noting the failure to file a return even after notice under section 148 and the non-participation in assessment proceedings, which showed negligence and a lackadaisical approach. Applying the principle that sufficient cause does not extend to inaction, negligence or absence of bona fides, it upheld the CIT(A)'s refusal to exercise discretion under section 249(3) and sustained dismissal of the appeal as time-barred.
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