Transfer pricing comparability requires functional alignment and permits working capital adjustment, while APA margins cannot govern non-covered years...
Treaty benefit, goodwill depreciation and hedging costs: export commission disallowed, while key business deductions and depreciation claims succeeded...
Undisclosed foreign asset classification requires an unexplained source; unrebutted affidavits and corroborative evidence defeated the Black Money Act...
The tribunal directed mandatory electronic filing and hearing of appeals on the government portal and prescribed staggered filing windows to avoid portal capacity and concurrency issues, allocating specific filing periods based on when first-instance appeals or revision notices were originally filed; the staggered schedule runs from 24.09.2025 to various deadlines not later than 30.06.2026. The measure invokes procedural rule powers to manage system load, applies to appeals under the CGST Act sections covering first appeals and revisions, and preserves the tribunal's substantive powers under the Act.
The tribunal directed mandatory electronic filing and hearing of appeals on the government portal and prescribed staggered filing windows to avoid portal capacity and concurrency issues, allocating specific filing periods based on when first-instance appeals or revision notices were originally filed; the staggered schedule runs from 24.09.2025 to various deadlines not later than 30.06.2026. The measure invokes procedural rule powers to manage system load, applies to appeals under the CGST Act sections covering first appeals and revisions, and preserves the tribunal's substantive powers under the Act.
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