Revenue neutrality in domestic related-party loans can require deletion of interest transfer pricing adjustments after domestic-transaction verificati...
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AAAR dismissed the appeal as time-barred. The Appellant filed the appeal 105 days after the last permissible date under Section 100(2) CGST Act (including the maximum 30-day condonable period in the proviso), exceeding AAAR's jurisdiction to condone delay. AAAR found the reasons for delay insufficient and held it lacked authority to extend the statutory limitation further; consequently the appeal was not admitted and the merits regarding eligibility to claim input tax credit for design, engineering, installation and operation of the 10.2 MW solar plant were not adjudicated. The appeal is therefore dismissed for want of prosecution ratione temporis without consideration of substantive issues.
AAAR dismissed the appeal as time-barred. The Appellant filed the appeal 105 days after the last permissible date under Section 100(2) CGST Act (including the maximum 30-day condonable period in the proviso), exceeding AAAR's jurisdiction to condone delay. AAAR found the reasons for delay insufficient and held it lacked authority to extend the statutory limitation further; consequently the appeal was not admitted and the merits regarding eligibility to claim input tax credit for design, engineering, installation and operation of the 10.2 MW solar plant were not adjudicated. The appeal is therefore dismissed for want of prosecution ratione temporis without consideration of substantive issues.
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