Business deductions and transfer pricing issues: tribunal treatment of software write-offs, donation receipts, warranty provisions, and related expens...
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CESTAT allowed the refund application, holding that the limitation period was validly extended by Supreme Court's COVID-19 order. The appellant's refund application filed on 12.04.2022 was deemed timely, as the period from 15.03.2020 to 28.02.2022 was explicitly excluded from limitation calculations. The tribunal criticized the Commissioner (Appeals) for being unaware of the Supreme Court's directive, ultimately dismissing the lower court's orders and granting the appellant's appeals.
CESTAT allowed the refund application, holding that the limitation period was validly extended by Supreme Court's COVID-19 order. The appellant's refund application filed on 12.04.2022 was deemed timely, as the period from 15.03.2020 to 28.02.2022 was explicitly excluded from limitation calculations. The tribunal criticized the Commissioner (Appeals) for being unaware of the Supreme Court's directive, ultimately dismissing the lower court's orders and granting the appellant's appeals.
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