Working-capital adjustment determines whether software-services transfer-pricing margins fall within the statutory tolerance range, eliminating any ad...
Permanent establishment deductions upheld for expatriate salaries, direct costs and trading losses, while head-office costs require fresh classificati...
Data transmission equipment classification under CTSH 8517 62 remains distinct from residual classification, with exemption evidence requiring scrutin...
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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