Dependent Agent PE unresolved for lack of factual inquiry; arm's-length distribution accepted; royalty claim rejected; 15% refund interest (Section 24...
Exemption under s.10(23C)(iiiad) upheld; appeal allowed, interest and dividends excluded from annual receipts, disallowance deleted, capital gains exe...
The HC held that principles of natural justice and valid service via the common GST portal were contested, but statutory time limits for condonation of delay are inflexible and appeal authorities cannot remit matters to the adjudicating authority; they may decide only on merits once delay is condoned. The court set aside the impugned order subject to the anonymized petitioner depositing Rs. 1,00,000/- lacs within one month; upon such deposit the impugned order shall stand suspended and the petitioner must file its reply within two weeks. The writ petition was disposed of accordingly, with the court reiterating that an appeal rejected as time-barred may reflect only refusal of condonation.
The HC held that principles of natural justice and valid service via the common GST portal were contested, but statutory time limits for condonation of delay are inflexible and appeal authorities cannot remit matters to the adjudicating authority; they may decide only on merits once delay is condoned. The court set aside the impugned order subject to the anonymized petitioner depositing Rs. 1,00,000/- lacs within one month; upon such deposit the impugned order shall stand suspended and the petitioner must file its reply within two weeks. The writ petition was disposed of accordingly, with the court reiterating that an appeal rejected as time-barred may reflect only refusal of condonation.
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