Patent-settlement expenditure treated as commercially expedient revenue outlay, with foreign-law restrictions inapplicable before the prospective amen...
International transaction benchmarking restricts transfer pricing adjustments to associated-enterprise dealings, while functional comparability govern...
Joint development agreements defer taxable transfer where possession lacks part performance, while completed flats determine consideration and exempti...
Passenger baggage re-export requires true declaration and cannot be granted indirectly through discretionary redemption of undeclared prohibited goods...
For GST appeals, limitation under Section 107 runs from communication of the specific order challenged and is not automatically suspended or restarted by a rectification petition. Statutory condonation limits cannot be enlarged through principles underlying Section 5 of the Limitation Act. Principles underlying Section 14 may nevertheless permit exclusion of time spent pursuing a rectification petition where it concerns the same parties and matter and was pursued with due diligence and good faith. Good faith requires an arguable rectification basis, not a meritless attempt to introduce material absent from the original proceedings. Where exclusion is established, the appeal period is computed after excluding the rectification period; otherwise, reconsideration may be subject to agreed remittance conditions.
For GST appeals, limitation under Section 107 runs from communication of the specific order challenged and is not automatically suspended or restarted by a rectification petition. Statutory condonation limits cannot be enlarged through principles underlying Section 5 of the Limitation Act. Principles underlying Section 14 may nevertheless permit exclusion of time spent pursuing a rectification petition where it concerns the same parties and matter and was pursued with due diligence and good faith. Good faith requires an arguable rectification basis, not a meritless attempt to introduce material absent from the original proceedings. Where exclusion is established, the appeal period is computed after excluding the rectification period; otherwise, reconsideration may be subject to agreed remittance conditions.
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