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...
Original order confirming GST demand was passed without opportunity of hearing. Appeal dismissed on limitation ground. Notification dated 02.11.2023 allows condonation of delay for appeals filed before 31.01.2024 against orders passed before 31.03.2023 u/ss 73/74 of GST Act. Impugned order passed on 20.07.2023, after 31.03.2023 cutoff date, hence notification inapplicable. Cited judgement deals with non-condonation of delay beyond statutory limitation period. Delay in filing appeal cannot be condoned beyond prescribed limitation under the Act. Petitions dismissed for lack of merit.
Original order confirming GST demand was passed without opportunity of hearing. Appeal dismissed on limitation ground. Notification dated 02.11.2023 allows condonation of delay for appeals filed before 31.01.2024 against orders passed before 31.03.2023 u/ss 73/74 of GST Act. Impugned order passed on 20.07.2023, after 31.03.2023 cutoff date, hence notification inapplicable. Cited judgement deals with non-condonation of delay beyond statutory limitation period. Delay in filing appeal cannot be condoned beyond prescribed limitation under the Act. Petitions dismissed for lack of merit.
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