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...
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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