Minimum alternate tax exclusions for pre-amendment banking companies and expatriate Indian branch salaries remain outside head office expenditure limi...
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HC allowed the appeal, finding the filing procedurally valid despite delay in certified copy submission. The court determined that online filing with electronic documents constitutes complete submission, and physical certification is not mandatory. Relying on precedent from Chegg India Private Limited, the HC held that technological advancements in filing systems should be interpreted liberally. The subsequent amendment to Rule 108(3) of CGST Rules, 2017 supports retrospective application, thereby validating the appellant's original submission. The court emphasized that technical procedural requirements should not impede substantive hearing of appeals on merits.
HC allowed the appeal, finding the filing procedurally valid despite delay in certified copy submission. The court determined that online filing with electronic documents constitutes complete submission, and physical certification is not mandatory. Relying on precedent from Chegg India Private Limited, the HC held that technological advancements in filing systems should be interpreted liberally. The subsequent amendment to Rule 108(3) of CGST Rules, 2017 supports retrospective application, thereby validating the appellant's original submission. The court emphasized that technical procedural requirements should not impede substantive hearing of appeals on merits.
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