Pre-amendment reassessment limitation bars late notices under the preserved regime, invalidating consequential reassessment for affected earlier asses...
Cash-sales explanations for bank deposits require documentary reconciliation; reassessment notice survived where effective response time was available...
Functional comparability in transfer pricing prevents ad hoc arm's length adjustments where functions, assets, risks and reliable comparables are unes...
Contingency expenses, exempt-income disallowance, and royalty benchmarking: unsupported adjustments were deleted under consistent accounting and trans...
Limitation u/s 107 of the BGST Act - Filing of Appeal before the Appellate Authority - The Court recognized the validity of Notification No. 53 of 2023, which extended the time for filing appeals until 31.01.2024. It emphasized the special procedure outlined in the notification, including the requirement to pay a portion of the disputed tax amount. - The Court directed the petitioner to comply with the conditions outlined in the notification to maintain the appeal. Failure to meet these conditions would result in the rejection of the appeal.
Limitation u/s 107 of the BGST Act - Filing of Appeal before the Appellate Authority - The Court recognized the validity of Notification No. 53 of 2023, which extended the time for filing appeals until 31.01.2024. It emphasized the special procedure outlined in the notification, including the requirement to pay a portion of the disputed tax amount. - The Court directed the petitioner to comply with the conditions outlined in the notification to maintain the appeal. Failure to meet these conditions would result in the rejection of the appeal.
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