Working-capital adjustment determines whether software-services transfer-pricing margins fall within the statutory tolerance range, eliminating any ad...
Permanent establishment deductions upheld for expatriate salaries, direct costs and trading losses, while head-office costs require fresh classificati...
Data transmission equipment classification under CTSH 8517 62 remains distinct from residual classification, with exemption evidence requiring scrutin...
The HC upheld the impugned order confirming tax liability on the deceased individual, rejecting the limitation plea under Section 74(10) of the GST Act by applying Section 9 of the General Clauses Act, 1897. The limitation period commenced from 06.02.2020, making the order dated 05.02.2025 timely. Procedural compliance was affirmed as notices were properly served and opportunities to respond were granted. No interference was warranted with the order. However, acknowledging the petitioner's potential liability under Section 93, the court granted leave to file a statutory appeal under Section 107 within 30 days of receipt of the order. The appeal was accordingly dismissed.
The HC upheld the impugned order confirming tax liability on the deceased individual, rejecting the limitation plea under Section 74(10) of the GST Act by applying Section 9 of the General Clauses Act, 1897. The limitation period commenced from 06.02.2020, making the order dated 05.02.2025 timely. Procedural compliance was affirmed as notices were properly served and opportunities to respond were granted. No interference was warranted with the order. However, acknowledging the petitioner's potential liability under Section 93, the court granted leave to file a statutory appeal under Section 107 within 30 days of receipt of the order. The appeal was accordingly dismissed.
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