Invocation of Explanation 7 to Section 271(1)(c) in blanket manner is contrary to purpose for which it was engrafted in statute

Pr CIT Vs. Verizon India Pvt. Ltd (Delhi High Court) The present appeal against the order dated 08.08.2016 of Income Tax Appellate Tribunal is barred because the revenue has refiled it with a delay of 550 days. On this ground alone, the appeal is liable to be rejected. This Court has considered the merits of the appeal as well. The brief facts are that during the relevant period, i.e. AY 2007-08, the assessee had, in the course of its return, relied upon a transfer pricing report. The report inter alia sought benefit of six comparables, by applying the Transactional Net Margin Method (TNMM) un...