Service permanent establishment requires non-auxiliary services, while arm's-length distributor remuneration precludes further profit attribution in I...
Make-available condition excludes standard SaaS subscription receipts where customers receive no independently usable technical knowledge after subscr...
Anonymous donation classification fails where charitable trusts maintain undisputed donor identity records and evidence corpus contributions' intended...
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Post-export shipping bill conversion remains available where contemporaneous evidence supports EPCG benefits despite curable procedural omissions and ...
An appellate authority must first examine limitation before considering the merits of a statutory appeal, and where delay is noticed the appellant must be given an opportunity to explain it and, where appropriate, seek condonation. Reliance on an electronic portal flag alone is insufficient if the appellant has not been heard on the issue of delay or the limitation computation may be erroneous. Here, the appeal was dismissed as time-barred after merits were heard and without raising a limitation objection earlier, so the petitioner was denied a fair opportunity. The appellate order was set aside and the matter remanded for fresh consideration on limitation and, if maintainable, on merits.
An appellate authority must first examine limitation before considering the merits of a statutory appeal, and where delay is noticed the appellant must be given an opportunity to explain it and, where appropriate, seek condonation. Reliance on an electronic portal flag alone is insufficient if the appellant has not been heard on the issue of delay or the limitation computation may be erroneous. Here, the appeal was dismissed as time-barred after merits were heard and without raising a limitation objection earlier, so the petitioner was denied a fair opportunity. The appellate order was set aside and the matter remanded for fresh consideration on limitation and, if maintainable, on merits.
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