Permanent establishment tests: independent subsidiary premises and principal-to-principal dealings did not create Indian taxability for offshore suppl...
Valuation Officer estimates govern property-value additions once statutory valuation is invoked, requiring fresh consideration of objections and compa...
Waiver of written show-cause notice may prevent a later procedural challenge after participation in customs adjudication, preserving statutory appella...
Retrospective invalidity of ocean-freight IGST supports refunds despite non-party status and prior credit utilisation, subject to authorised appeal gr...
Additional evidence in departmental appeals may include show-cause-notice material without introducing a new case where it merely corroborates existin...
Reasoned rectification orders require consideration of expenditure disclosed in income-tax returns, preventing revision based on incomplete income com...
Modified returns after business reorganisations cannot trigger fresh scrutiny once the original assessment was complete, invalidating related transfer...
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Condonation of delay in filing appeal - The correct date of communication of the Order-in-Original is on record i.e. 07.05.2019, it is clear that the Appeal though filed beyond the statutory period, but was field within the condonable period. Accordingly, the delay is condoned in filing the Appeals before the First Appellate Authority and find it appropriate to remand the matter to the Ld.Commissioner(Appeals) to decide the Appeals on merits without further visiting the aspect of limitation. - AT
Condonation of delay in filing appeal - The correct date of communication of the Order-in-Original is on record i.e. 07.05.2019, it is clear that the Appeal though filed beyond the statutory period, but was field within the condonable period. Accordingly, the delay is condoned in filing the Appeals before the First Appellate Authority and find it appropriate to remand the matter to the Ld.Commissioner(Appeals) to decide the Appeals on merits without further visiting the aspect of limitation. - AT
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