Transfer pricing comparability requires functional alignment, reliable financial data, and careful review of working capital and receivables adjustmen...
Transfer pricing rules require benchmarking corporate guarantees and associated-enterprise advances, while invalid domestic-transaction adjustments ca...
Prospective sugar export prohibition required registered letters of credit; private contracts and export quotas created no enforceable continuation ri...
HC allowed the writ petition, quashing the appellate order that rejected an appeal solely on grounds of delay. The court emphasized that limitation provisions warrant liberal interpretation where genuine hardships exist. Despite petitioner's unawareness of the earlier appeal's rejection leading to a missed deadline under Notification No. 53/2023, the delay was not deliberate. The appellate authority erred by rejecting the appeal without considering the condonation application. Given the procedural irregularities and arbitrary nature of the rejection, particularly after full payment of disputed tax, the court found merit in petitioner's case and set aside the impugned order.
HC allowed the writ petition, quashing the appellate order that rejected an appeal solely on grounds of delay. The court emphasized that limitation provisions warrant liberal interpretation where genuine hardships exist. Despite petitioner's unawareness of the earlier appeal's rejection leading to a missed deadline under Notification No. 53/2023, the delay was not deliberate. The appellate authority erred by rejecting the appeal without considering the condonation application. Given the procedural irregularities and arbitrary nature of the rejection, particularly after full payment of disputed tax, the court found merit in petitioner's case and set aside the impugned order.
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