Transfer pricing comparability requires functional alignment and permits working capital adjustment, while APA margins cannot govern non-covered years...
Treaty benefit, goodwill depreciation and hedging costs: export commission disallowed, while key business deductions and depreciation claims succeeded...
Undisclosed foreign asset classification requires an unexplained source; unrebutted affidavits and corroborative evidence defeated the Black Money Act...
The High Court considered the issue of condonation of delay in filing an appeal u/s 107 of the UPGST Act, 2017. The appeal was dismissed as time-barred, but the Court found the department's approach overly technical. The Court noted that filing within the extended time was crucial, with hard copies to follow. Citing precedent, the Court emphasized the need for the petitioner to justify the delay adequately. The Court quashed the order and directed the appellate authority to allow the petitioner another opportunity to submit medical documents before deciding on the delay application. The writ petition was disposed of accordingly.
The High Court considered the issue of condonation of delay in filing an appeal u/s 107 of the UPGST Act, 2017. The appeal was dismissed as time-barred, but the Court found the department's approach overly technical. The Court noted that filing within the extended time was crucial, with hard copies to follow. Citing precedent, the Court emphasized the need for the petitioner to justify the delay adequately. The Court quashed the order and directed the appellate authority to allow the petitioner another opportunity to submit medical documents before deciding on the delay application. The writ petition was disposed of accordingly.
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