SEZ-unit profit deduction covers voluntary transfer-pricing adjustments, while exempt-income costs, foreign-exchange loss and ITeS comparables are exa...
Infrastructure-development deduction remains available to EPC contractors when substantive statutory conditions outweigh contractor labels in agreemen...
Explained Investment Sources: documented gifts and traceable salary savings supported deletion of additions for property and mutual-fund SIP investmen...
Internal comparable pricing supports arm's-length interest on compulsorily convertible debentures, preventing their recharacterisation as equity for t...
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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