Transfer-pricing comparability permits fresh objections and filters where software service comparables are functionally unsuitable for arm's-length pr...
Territorial rendering requirement excludes China-based management and consultancy services from fees for technical services under the India-China DTAA...
FEMA borrowing restrictions bind charitable trusts, and civil penalties apply without proving intent for delayed repayment of non-resident rupee loans...
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.
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TaxTMI 
TaxTMI 
of 4915 
