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...
Condonation of delay under the proviso to Section 100(2) of the CGST Act is discussed with focus on technical portal failure as sufficient cause; the note explains that repeated unsuccessful online filing attempts, corroborated by screenshots and a helpdesk ticket, can satisfy the requirement of prevention from presenting an appeal within the primary period and justify admission within the further thirty days. It states that, where such evidence is accepted, the appellate authority may invoke its power to condone delay and admit the appeal for adjudication on merits.
Condonation of delay under the proviso to Section 100(2) of the CGST Act is discussed with focus on technical portal failure as sufficient cause; the note explains that repeated unsuccessful online filing attempts, corroborated by screenshots and a helpdesk ticket, can satisfy the requirement of prevention from presenting an appeal within the primary period and justify admission within the further thirty days. It states that, where such evidence is accepted, the appellate authority may invoke its power to condone delay and admit the appeal for adjudication on merits.
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