Separate speaking orders on reopening objections are mandatory; deciding them within reassessment invalidates jurisdiction and precludes revival of st...
Compulsorily convertible debentures remain debt before conversion, preventing transfer-pricing and interest-deduction disallowances on the stated fact...
Statutory outer limits on condonation of delay in GST registration-cancellation appeals confine the First Appellate Authority to the power expressly granted. Constitutional-court directions issued in extraordinary jurisdiction cannot enlarge that statutory power, and equity or substantial justice cannot displace the prescribed limit; appeals entertained after that limit are without jurisdiction. Where the Department has implemented appellate orders by restoring cancelled registrations, its own challenge becomes infructuous because the restored legal and commercial position cannot be unsettled without affecting intervening transactions. Such departmental appeals are not maintainable after implementation of the impugned orders.
Statutory outer limits on condonation of delay in GST registration-cancellation appeals confine the First Appellate Authority to the power expressly granted. Constitutional-court directions issued in extraordinary jurisdiction cannot enlarge that statutory power, and equity or substantial justice cannot displace the prescribed limit; appeals entertained after that limit are without jurisdiction. Where the Department has implemented appellate orders by restoring cancelled registrations, its own challenge becomes infructuous because the restored legal and commercial position cannot be unsettled without affecting intervening transactions. Such departmental appeals are not maintainable after implementation of the impugned orders.
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