Supervisory permanent establishment requires project-wise duration and qualifying construction nexus; offshore supplies and salary reimbursements rema...
Transfer-pricing comparability permits fresh objections and filters where software service comparables are functionally unsuitable for arm's-length pr...
Territorial rendering requirement excludes China-based management and consultancy services from fees for technical services under the India-China DTAA...
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HC determined the appeal delay was justifiable in a GST input tax credit dispute. The appellant had deposited pre-requisite amounts before formal appeal dismissal. Manual filing was permissible in December 2022 with no prohibition notifications. Electronic filing was impossible until the order's upload on GST portal on 17.01.2023. The appellant complied with Section 107(6b) of CGST Act by depositing Rs.82,000 in GST Electronic Cash Ledger and submitting via speed post. The Court condoned the delay, noting substantial compliance with statutory requirements including 10% pre-deposit of tax liability. The procedural delay was deemed insufficient grounds for dismissal given the appellant's efforts to meet statutory obligations. Petition allowed.
HC determined the appeal delay was justifiable in a GST input tax credit dispute. The appellant had deposited pre-requisite amounts before formal appeal dismissal. Manual filing was permissible in December 2022 with no prohibition notifications. Electronic filing was impossible until the order's upload on GST portal on 17.01.2023. The appellant complied with Section 107(6b) of CGST Act by depositing Rs.82,000 in GST Electronic Cash Ledger and submitting via speed post. The Court condoned the delay, noting substantial compliance with statutory requirements including 10% pre-deposit of tax liability. The procedural delay was deemed insufficient grounds for dismissal given the appellant's efforts to meet statutory obligations. Petition allowed.
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