Risk-based selective vessel boarding requires accurate declarations and preserves master and agent liability where physical inspections are not select...
Permanent-establishment reassessment cannot revisit scrutinised disclosures; extended reopening fails without undisclosed material facts and within st...
Modified returns after business reorganisation must be assessed within pending proceedings, barring parallel scrutiny and consequential transfer prici...
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Section 107 of the CGST Act confines GST appeals to a three-month filing period, with condonation by the Appellate Authority limited to one further month upon sufficient cause. Section 5 of the Limitation Act cannot enlarge that statutory ceiling. Limitation runs from communication; portal availability and postal service under Section 169 may require factual scrutiny, while Rule 108 governs electronic or permitted manual filing where an order is unavailable on the portal. Statutory pre-deposit triggers a deemed stay of recovery for the balance demand. Article 226 may exceptionally restore an unheard appeal where defective communication, prompt action after knowledge and material procedural unfairness justify relief, but is not a routine cure for delay or inaction.
Section 107 of the CGST Act confines GST appeals to a three-month filing period, with condonation by the Appellate Authority limited to one further month upon sufficient cause. Section 5 of the Limitation Act cannot enlarge that statutory ceiling. Limitation runs from communication; portal availability and postal service under Section 169 may require factual scrutiny, while Rule 108 governs electronic or permitted manual filing where an order is unavailable on the portal. Statutory pre-deposit triggers a deemed stay of recovery for the balance demand. Article 226 may exceptionally restore an unheard appeal where defective communication, prompt action after knowledge and material procedural unfairness justify relief, but is not a routine cure for delay or inaction.
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