Service permanent establishment requires non-auxiliary services, while arm's-length distributor remuneration precludes further profit attribution in I...
Make-available condition excludes standard SaaS subscription receipts where customers receive no independently usable technical knowledge after subscr...
Anonymous donation classification fails where charitable trusts maintain undisputed donor identity records and evidence corpus contributions' intended...
Transfer pricing method selection favours TNMM where medical-equipment distribution involves substantial post-import value addition and operational ri...
Rejection of refund on the ground of delay - time limitation - The High Court examined the timeline of the refund applications in light of the Covid-19 pandemic's impact on statutory limitations. It noted that the applications were indeed filed within the extended timeframe provided by the Government Notification No.13 of 2022, which suspended limitations from February 15, 2020, to February 28, 2022. The Court cited a precedent case, Gamma Gaana Ltd. vs. Union of India, to reinforce this interpretation. - The Court directed the authority to process the refund applications without objections regarding delay.
Rejection of refund on the ground of delay - time limitation - The High Court examined the timeline of the refund applications in light of the Covid-19 pandemic's impact on statutory limitations. It noted that the applications were indeed filed within the extended timeframe provided by the Government Notification No.13 of 2022, which suspended limitations from February 15, 2020, to February 28, 2022. The Court cited a precedent case, Gamma Gaana Ltd. vs. Union of India, to reinforce this interpretation. - The Court directed the authority to process the refund applications without objections regarding delay.
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