Transfer pricing comparability requires functional alignment, reliable financial data, and careful review of working capital and receivables adjustmen...
Transfer pricing rules require benchmarking corporate guarantees and associated-enterprise advances, while invalid domestic-transaction adjustments ca...
Prospective sugar export prohibition required registered letters of credit; private contracts and export quotas created no enforceable continuation ri...
Retroactive interim-moratorium exclusion permits protective asset disclosure and preservation measures against personal guarantors pending arbitration...
Notification No. 53/2023-Central Tax provides a special procedure for GST appeals filed beyond the ordinary limitation period where the appeal falls within the extended filing period and satisfies the prescribed payment condition. Its scope covers taxpayers unable to file within the statutory period, delayed appeals rejected as time-barred, and qualifying pending appeals arising from orders under sections 73 and 74. A qualifying appeal filed by 31 January 2024 cannot be treated less favourably than an appeal previously rejected solely for delay. Rejection without considering the Notification was treated as unsustainable, requiring remand for a merits determination.
Notification No. 53/2023-Central Tax provides a special procedure for GST appeals filed beyond the ordinary limitation period where the appeal falls within the extended filing period and satisfies the prescribed payment condition. Its scope covers taxpayers unable to file within the statutory period, delayed appeals rejected as time-barred, and qualifying pending appeals arising from orders under sections 73 and 74. A qualifying appeal filed by 31 January 2024 cannot be treated less favourably than an appeal previously rejected solely for delay. Rejection without considering the Notification was treated as unsustainable, requiring remand for a merits determination.
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