2015 (8) TMI 661

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.... CM No.8217/2015 (for condonation of delay of 526 days in re-filing the appeal) 1. There is an inordinate delay of 526 days i.e. more than a year and five months in the re-filing of the present appeal by the Revenue. 2. The Court finds that there are three standard excuses that the Revenue is putting forth in all such applications for condonation of delay in re-filing. The first is regarding....

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....to facilitate the making of soft copies so that the inconvenience if any caused to the Advocates and the litigants is minimised. The third excuse regarding change of standing counsel is also not justified considering that there is an entire panel of lawyers for the Revenue and its cell in the High Court is managed by a Deputy CIT whose work is overseen by an Assistant CIT. None of the above factor....

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....sion in Explanation 2 to Section 10B. Secondly, as pointed out by the learned counsel for the Assessee Section, 10B (4) envisages that some part of the profits derived by 100 per cent export unit could be relatable to 'export turnover', as distinguished from total turnover. Further, it is seen that in Commissioner of Income v. Genpact India (2011) 203 Taxman 632 (Delhi), this Court, while ....