Transfer pricing comparability requires functional alignment and permits working capital adjustment, while APA margins cannot govern non-covered years...
Treaty benefit, goodwill depreciation and hedging costs: export commission disallowed, while key business deductions and depreciation claims succeeded...
Undisclosed foreign asset classification requires an unexplained source; unrebutted affidavits and corroborative evidence defeated the Black Money Act...
Under the GST appellate scheme, the High Court held that the statute is a self-contained code and the appellate authority can condone delay only up to one additional month beyond the prescribed three-month period. Because the outer limit is fixed by the GST Act, Section 5 of the Limitation Act is impliedly excluded and cannot be used to enlarge time further. An appeal filed beyond that maximum condonable period is outside jurisdiction, so the appellate order was left undisturbed and the writ petition was dismissed.
Under the GST appellate scheme, the High Court held that the statute is a self-contained code and the appellate authority can condone delay only up to one additional month beyond the prescribed three-month period. Because the outer limit is fixed by the GST Act, Section 5 of the Limitation Act is impliedly excluded and cannot be used to enlarge time further. An appeal filed beyond that maximum condonable period is outside jurisdiction, so the appellate order was left undisturbed and the writ petition was dismissed.
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