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...
Mandatory electronic upload of the summary of an adjudication order under GST is required to preserve the taxpayer's statutory right of appeal, and the appellate authority cannot treat an appeal as time-barred where that summary was issued later. Following its earlier view and the Supreme Court's principle in ASP Traders, the HC held that reliance only on an earlier email transmission was insufficient in the circumstances. The appellate order rejecting the appeal on limitation was quashed, and the matter was remitted for fresh disposal on merits without reference to limitation.
Mandatory electronic upload of the summary of an adjudication order under GST is required to preserve the taxpayer's statutory right of appeal, and the appellate authority cannot treat an appeal as time-barred where that summary was issued later. Following its earlier view and the Supreme Court's principle in ASP Traders, the HC held that reliance only on an earlier email transmission was insufficient in the circumstances. The appellate order rejecting the appeal on limitation was quashed, and the matter was remitted for fresh disposal on merits without reference to limitation.
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