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...
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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