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...
Transitional applicability of the appellate pre-deposit requirement depends on the law in force when adjudicatory proceedings commenced through issuance of the show-cause notice. Appeals against penalty orders arising from notices issued before substitution of the proviso to Section 107(6) of the CGST Act remain governed by the earlier pre-deposit provision. Petitioners must pursue the statutory appellate remedy, with physical filing accepted where electronic filing is unavailable because no individual registration or temporary identification exists. The merits, including whether penalty provisions apply to a person who is not taxable, remain open for determination in accordance with the Supreme Court's ultimate decision.
Transitional applicability of the appellate pre-deposit requirement depends on the law in force when adjudicatory proceedings commenced through issuance of the show-cause notice. Appeals against penalty orders arising from notices issued before substitution of the proviso to Section 107(6) of the CGST Act remain governed by the earlier pre-deposit provision. Petitioners must pursue the statutory appellate remedy, with physical filing accepted where electronic filing is unavailable because no individual registration or temporary identification exists. The merits, including whether penalty provisions apply to a person who is not taxable, remain open for determination in accordance with the Supreme Court's ultimate decision.
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