Transfer pricing comparables must reflect functional similarity, with diverse activities and asset profiles supporting exclusion from contract service...
Real income in electricity distribution excludes surcharges and regulatory assets without reasonably certain recovery, while deductions require return...
Contempt for company bank account restraint breaches requires deliberate disobedience, while contempt appeals are limited to orders imposing punishmen...
A waiver application under Notification No. 21/2024-Central Tax was treated by the High Court as subject to a directory, not mandatory, three-month filing period because the notification used the word may. The rejection of the application solely on the ground of delay was therefore based on an erroneous interpretation of law. The Court quashed the rejection in FORM GST SPL-07 and directed the authority to reconsider the waiver application on merits in accordance with law, while keeping the show cause notice, summary notice and order in original in abeyance until that reconsideration.
A waiver application under Notification No. 21/2024-Central Tax was treated by the High Court as subject to a directory, not mandatory, three-month filing period because the notification used the word may. The rejection of the application solely on the ground of delay was therefore based on an erroneous interpretation of law. The Court quashed the rejection in FORM GST SPL-07 and directed the authority to reconsider the waiver application on merits in accordance with law, while keeping the show cause notice, summary notice and order in original in abeyance until that reconsideration.
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