Transfer pricing comparability requires functional alignment, reliable financial data, and careful review of working capital and receivables adjustmen...
Transfer pricing rules require benchmarking corporate guarantees and associated-enterprise advances, while invalid domestic-transaction adjustments ca...
Prospective sugar export prohibition required registered letters of credit; private contracts and export quotas created no enforceable continuation ri...
Retroactive interim-moratorium exclusion permits protective asset disclosure and preservation measures against personal guarantors pending arbitration...
Maintainability of appeal before the appellate authority - time limitation - The High Court held that, appellate authorities under such statutes are not vested with the jurisdiction to condone delays beyond the permissible statutory period. It was also noted that the CGST Act is a special statute and a self-contained code by itself, which impliedly excludes the application of the Limitation Act, 1963. Therefore, Section 5 of the Limitation Act, which provides for the condonation of delay, does not apply to Section 107 of the CGST Act.
Maintainability of appeal before the appellate authority - time limitation - The High Court held that, appellate authorities under such statutes are not vested with the jurisdiction to condone delays beyond the permissible statutory period. It was also noted that the CGST Act is a special statute and a self-contained code by itself, which impliedly excludes the application of the Limitation Act, 1963. Therefore, Section 5 of the Limitation Act, which provides for the condonation of delay, does not apply to Section 107 of the CGST Act.
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