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...
The Court held that time spent bona fide pursuing GST appellate relief before a wrong forum could be excluded under Section 14 of the Limitation Act, and that this question was distinct from condonation under Section 5. It distinguished authorities on Section 5 as dealing with self-contained special limitation schemes, not exclusion of time under Section 14. Applying the principle in Prakash Medical Stores, the Court found the petitioner had genuinely pursued the appeal before the Commissioner, CGST, Kanpur, and that period could not be ignored in computing limitation. The order rejecting the appeal as time-barred was set aside and the matter remitted for fresh decision.
The Court held that time spent bona fide pursuing GST appellate relief before a wrong forum could be excluded under Section 14 of the Limitation Act, and that this question was distinct from condonation under Section 5. It distinguished authorities on Section 5 as dealing with self-contained special limitation schemes, not exclusion of time under Section 14. Applying the principle in Prakash Medical Stores, the Court found the petitioner had genuinely pursued the appeal before the Commissioner, CGST, Kanpur, and that period could not be ignored in computing limitation. The order rejecting the appeal as time-barred was set aside and the matter remitted for fresh decision.
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