Gross-profit additions on disputed purchases require reasoned appellate determination; disclosed claims alone do not support inaccurate-particulars pe...
Limitation after transfer-pricing remand: fresh TPO reference did not extend the assessment deadline, rendering the consequential assessment time-barr...
Interim judicial restraint on tax deduction prevents default, while supporting reasonable cause and penalty deletion for foreign-leg LFC reimbursement...
Palmolein classification defeated the crude-oil concession; material misdeclaration sustained recovery and confiscation, while separate false-document...
Condonation of extraordinary delay in re-presenting departmental tax appeals requires a reasonable, plausible and bona fide explanation supported by a coherent account of the period of inaction. General assertions of administrative workload, simultaneous appeal filings, voluminous records and procedural requirements do not establish sufficient cause. Delay in re-presentation is assessed less rigorously than delay under the Limitation Act, but government departments receive no preferential treatment and must show diligence and bona fide effort. The condonation applications were dismissed, and the departmental appeals were rejected.
Condonation of extraordinary delay in re-presenting departmental tax appeals requires a reasonable, plausible and bona fide explanation supported by a coherent account of the period of inaction. General assertions of administrative workload, simultaneous appeal filings, voluminous records and procedural requirements do not establish sufficient cause. Delay in re-presentation is assessed less rigorously than delay under the Limitation Act, but government departments receive no preferential treatment and must show diligence and bona fide effort. The condonation applications were dismissed, and the departmental appeals were rejected.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4907 
