Transfer pricing comparables and operating income principles applied to software development services, with exclusions, inclusions, and tax credit ver...
Transfer pricing on performance guarantees and overdue receivables deleted where warranty obligations were embedded and working capital adjustment alr...
The case involved a challenge to the time limitation for filing an appeal under Section 107 of the UPGST Act. The High Court held that limitation provisions in tax laws serve to ensure timely compliance, discourage delays, and promote equal treatment of taxpayers. The petitioner received the order on July 12, 2022, and filed the appeal on November 10, 2022. The court found errors in the calculation of the time limit by the authorities, warranting the exercise of writ jurisdiction. The court directed the appellate authority to allow the delay in filing the appeal and proceed to hear the appeal on merits promptly, preferably within two months. The application was disposed of accordingly.
The case involved a challenge to the time limitation for filing an appeal under Section 107 of the UPGST Act. The High Court held that limitation provisions in tax laws serve to ensure timely compliance, discourage delays, and promote equal treatment of taxpayers. The petitioner received the order on July 12, 2022, and filed the appeal on November 10, 2022. The court found errors in the calculation of the time limit by the authorities, warranting the exercise of writ jurisdiction. The court directed the appellate authority to allow the delay in filing the appeal and proceed to hear the appeal on merits promptly, preferably within two months. The application was disposed of accordingly.
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