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Transfer pricing comparability requires functional alignment and permits working capital adjustment, while APA margins cannot govern non-covered years...
For limitation purposes, a dealer's declared date of communication of an adjudication order must be treated as the actual communication date unless the Revenue rebuts it with cogent material. Treating the order date itself as the communication date, despite an unrebutted assertion of later receipt, cannot justify dismissal of the statutory appeal as time-barred. The appellate order was quashed, and the appeal was remitted to the appellate authority for fresh consideration after hearing the parties.
For limitation purposes, a dealer's declared date of communication of an adjudication order must be treated as the actual communication date unless the Revenue rebuts it with cogent material. Treating the order date itself as the communication date, despite an unrebutted assertion of later receipt, cannot justify dismissal of the statutory appeal as time-barred. The appellate order was quashed, and the appeal was remitted to the appellate authority for fresh consideration after hearing the parties.
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