Charitable trust registration requires a specified-violation notice; settled cash deposits and related-party payments did not justify cancellation or ...
External development charges trigger TDS under section 194C, while disputed administrative payments require factual verification and fresh adjudicatio...
Section 270AA penalty immunity requires identified statutory defaults and a hearing before rejection; reassessment disclosure may constitute under-rep...
Section 80JJAA employee-cost deduction allowed for deployed staff but barred against transfer-pricing income enhancement, with pricing issues remanded...
Transfer-pricing methodology protects commercially genuine associated-enterprise payments, while pre-2016 secondary adjustments and related notional i...
Negative liens over operating assets can constitute international transactions requiring arm's-length pricing reflecting restricted borrowing and expa...
Cross-examination rights in Customs Broker revocation inquiries require witness examination; procedural denial may be cured through fresh adjudication...
Determination of time limit for filing of Appeal before the Appellate Authority - Delay due to the online system's failure to upload the Order-in-Original with the appeal. - Condonation of delay - The High Court found that the appeal was filed within the three-month limitation period, contrary to the Appellate Authority's ruling. The Court noted that the Order-in-Original was indeed uploaded with the appeal, contrary to the earlier technical glitch claimed by the respondents. The High Court upheld the petitioner's argument regarding the interpretation of Rule 108(3) and deemed the appeal filed on the date of online submission, i.e., 12.11.2022. In applying Section 12 of the Limitation Act, the Court excluded certain periods, ultimately concluding that the appeal was within the limitation period.
Determination of time limit for filing of Appeal before the Appellate Authority - Delay due to the online system's failure to upload the Order-in-Original with the appeal. - Condonation of delay - The High Court found that the appeal was filed within the three-month limitation period, contrary to the Appellate Authority's ruling. The Court noted that the Order-in-Original was indeed uploaded with the appeal, contrary to the earlier technical glitch claimed by the respondents. The High Court upheld the petitioner's argument regarding the interpretation of Rule 108(3) and deemed the appeal filed on the date of online submission, i.e., 12.11.2022. In applying Section 12 of the Limitation Act, the Court excluded certain periods, ultimately concluding that the appeal was within the limitation period.
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