Supervisory permanent establishment requires project-wise duration and qualifying construction nexus; offshore supplies and salary reimbursements rema...
Transfer-pricing comparability permits fresh objections and filters where software service comparables are functionally unsuitable for arm's-length pr...
Territorial rendering requirement excludes China-based management and consultancy services from fees for technical services under the India-China DTAA...
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The HC set aside the Appellate Authority's impugned order and remitted the matter for fresh consideration of the applicant's prayer for condonation of delay under s.107(4) of the GST Act, 2017. The Court held that the Appellate Authority possesses jurisdiction to condone delay beyond the statutory period, subject to the presentation of a satisfactory explanation and opportunity to adduce evidence. The HC distinguished precedents under the Central Excise Act as inapplicable, and noted a Division Bench ruling treating the limitation in s.107(4) as directory and that an interim stay by the apex court does not constitute a binding declaration of law. Petition disposed; fresh hearing directed.
The HC set aside the Appellate Authority's impugned order and remitted the matter for fresh consideration of the applicant's prayer for condonation of delay under s.107(4) of the GST Act, 2017. The Court held that the Appellate Authority possesses jurisdiction to condone delay beyond the statutory period, subject to the presentation of a satisfactory explanation and opportunity to adduce evidence. The HC distinguished precedents under the Central Excise Act as inapplicable, and noted a Division Bench ruling treating the limitation in s.107(4) as directory and that an interim stay by the apex court does not constitute a binding declaration of law. Petition disposed; fresh hearing directed.
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