Transfer pricing comparability under TNMM: foreign exchange loss on ECB excluded from operating cost, and a functionally dissimilar comparator removed...
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Rejection of appeal filed by the petitioner - time limitation - self-certified copy of the decision or order was not made available within time as per proviso to Rule 108 of the GST Act - The High Court concluded that the appeal should not be dismissed solely for the delay in filing the certified copy within seven days. The court quashed the impugned order and directed the appellate authority to rehear the appeals and issue a reasoned decision on the merits within three months.
Rejection of appeal filed by the petitioner - time limitation - self-certified copy of the decision or order was not made available within time as per proviso to Rule 108 of the GST Act - The High Court concluded that the appeal should not be dismissed solely for the delay in filing the certified copy within seven days. The court quashed the impugned order and directed the appellate authority to rehear the appeals and issue a reasoned decision on the merits within three months.
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