Transfer pricing comparability requires functional alignment and permits working capital adjustment, while APA margins cannot govern non-covered years...
Treaty benefit, goodwill depreciation and hedging costs: export commission disallowed, while key business deductions and depreciation claims succeeded...
Undisclosed foreign asset classification requires an unexplained source; unrebutted affidavits and corroborative evidence defeated the Black Money Act...
Maintainability of appeal - time limitation - It is undisputed fact on record that as the petitioner has received the Assessment Order on 21.11.2019, the last date for filing of appeal was 20th March, 2020 which fell within the condonable period of limitation specified under Section 107(4) of the CGST Act and appeal being filed on 26th July, 2021, the appeal should have been treated as filed within the period of limitation in view of Category- III specified in the Order dated 23.09.2021 of the Hon’ble Apex Court. - HC
Maintainability of appeal - time limitation - It is undisputed fact on record that as the petitioner has received the Assessment Order on 21.11.2019, the last date for filing of appeal was 20th March, 2020 which fell within the condonable period of limitation specified under Section 107(4) of the CGST Act and appeal being filed on 26th July, 2021, the appeal should have been treated as filed within the period of limitation in view of Category- III specified in the Order dated 23.09.2021 of the Hon’ble Apex Court. - HC
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