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2016 (9) TMI 1645 - HC - Income TaxDelay of 620 days - grounds for condonation of delay are that there was reorganisation of the panel, that counsel did not hand over the files to the revenue’s officials upon their receiving them after such reorganisation and the difficulties it underwent on account of transition during the e-filing phase. These reasons are unpersuasive – they are similar to the reasons rejected in a number of other cases (See CIT vs. Dion Global Solutions Ltd.[2015 (8) TMI 175 - DELHI HIGH COURT] Whether embedded software can be segregated for the purpose of separate assessment? - Issue is no longer res-integra and is the subject matter of a division bench ruling in Director of Income Tax vs. Ericsson, A.B.. [2011 (12) TMI 91 - DELHI HIGH COURT] against the revenue.
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