June 1976 and was hit by the doctrine of
'impossibility of performance'."
The additional grounds raised by the assessee ... subsequent amendments made in the Act with retrospective effect
(i.e. impossibility of performance); and
IT(TP)A Nos. 1557/Bang/2012 and
259/Bang
date of compliance i.e. October 31,
2006 resulting in 'impossibility of performance' and against the
premise of maintenance of 'contemporaneous documentation ... beyond the date of compliance i.e., 31.10.2006 resulting in
impossibility of performance and against the premise of maintenance of
contemporaneous documentation and also exercised
impossibility of
performance as the judgement in the case of Samsung
Electronic Company Ltd was pronounced on 15.10,2011
much after the current financial
conducting a fresh
comparability analysis without appreciating the fact of impossibility of
performance.
3. The learned TPO / Hon'ble DRP erred in rejecting
orders are hit by the doctrine of
impossibility of performance on the facts of the case
e) Rejecting companies having different financial year ending
June 1976 and was hit by the doctrine of 'impossibility of
performance'."
The additional grounds raised by the assessee
June 1976 and was hit by the doctrine of
'impossibility of performance'."
The additional grounds raised by the assessee
M/S Honeywell Technology Solutions Lab ... vs Deputy Commissioner Of Income Tax ... on 7 January
does not
demand the impossible and impotentiaexcusatlegem, i.e., when there is
a disability that makes it impossible to obey the law, the alleged
disobedience ... following decisions, Courts have recognised the principles
of impossibility of performance:
→ Dalmia Power Ltd., vs. ACIT (2020) 420 ITR 339 (SC) [Para
8];
→ Life Insurance
Cess, as the revised
return could not be filed due to impossibility of performance.
ITA No.1054/Bang/2024
IIFL Samasta Finance Limited, Bangalore
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