Pre-amendment reassessment limitation bars late notices under the preserved regime, invalidating consequential reassessment for affected earlier asses...
Cash-sales explanations for bank deposits require documentary reconciliation; reassessment notice survived where effective response time was available...
Functional comparability in transfer pricing prevents ad hoc arm's length adjustments where functions, assets, risks and reliable comparables are unes...
Contingency expenses, exempt-income disallowance, and royalty benchmarking: unsupported adjustments were deleted under consistent accounting and trans...
HC quashed the appellate authority's order rejecting petitioner's appeal as time-barred under CGST Act. Petitioner attempted filing appeal within statutory period under Section 107 but was prevented by system malfunction that rejected appeals where demanded tax was already paid. Despite petitioner's protest payment and timely filing attempt, authorities failed to address technical impediment. Court held denial of statutory remedy was attributable solely to respondents' defective system, not petitioner's conduct. Appellate authority erred in mechanically applying time limitation without considering circumstances preventing timely submission. HC directed restoration of appeal and consideration on merits, treating it as timely filed, recognizing petitioner's right to appeal remains despite tax payment under protest.
HC quashed the appellate authority's order rejecting petitioner's appeal as time-barred under CGST Act. Petitioner attempted filing appeal within statutory period under Section 107 but was prevented by system malfunction that rejected appeals where demanded tax was already paid. Despite petitioner's protest payment and timely filing attempt, authorities failed to address technical impediment. Court held denial of statutory remedy was attributable solely to respondents' defective system, not petitioner's conduct. Appellate authority erred in mechanically applying time limitation without considering circumstances preventing timely submission. HC directed restoration of appeal and consideration on merits, treating it as timely filed, recognizing petitioner's right to appeal remains despite tax payment under protest.
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