Working-capital adjustment determines whether software-services transfer-pricing margins fall within the statutory tolerance range, eliminating any ad...
Permanent establishment deductions upheld for expatriate salaries, direct costs and trading losses, while head-office costs require fresh classificati...
Data transmission equipment classification under CTSH 8517 62 remains distinct from residual classification, with exemption evidence requiring scrutin...
Delay in filing a statutory GST appeal was condoned in writ jurisdiction where the assessee showed that non-filing within time was due to circumstances beyond its control. The Court held that, although the Appellate Authority is bound by the limitation under Section 107 of the RGST/CGST Act, refusal to permit consideration on merits in such circumstances would cause grave prejudice. The delay was therefore condoned and the Appellate Authority was directed to entertain and decide the appeal on merits. The challenge to the vires of Section 107(4) read with the notification was not pressed and was left open.
Delay in filing a statutory GST appeal was condoned in writ jurisdiction where the assessee showed that non-filing within time was due to circumstances beyond its control. The Court held that, although the Appellate Authority is bound by the limitation under Section 107 of the RGST/CGST Act, refusal to permit consideration on merits in such circumstances would cause grave prejudice. The delay was therefore condoned and the Appellate Authority was directed to entertain and decide the appeal on merits. The challenge to the vires of Section 107(4) read with the notification was not pressed and was left open.
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