Constitutional personal-liberty safeguards limit PMLA twin bail conditions where completed investigations lead to prolonged incarceration before trial...
Automated airline software subscriptions without human intervention fail technical-services characterisation and do not make available underlying tech...
Business support recruitment and training receipts qualify for presumptive business taxation, not professional taxation under technical consultancy ru...
Treaty exemption for foreign permanent-establishment management fees prevailed, while dividend expense disallowance remained limited to an accepted al...
Centralised assessment transfers: participation after requesting centralisation can bar technical jurisdictional challenges, while assessment disputes...
Binding precedent remains operative despite pending challenge, supporting deletion of interest disallowance when debt is converted into preference sha...
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Section 107 of the CGST Act confines GST appeals to a three-month filing period, with condonation by the Appellate Authority limited to one further month upon sufficient cause. Section 5 of the Limitation Act cannot enlarge that statutory ceiling. Limitation runs from communication; portal availability and postal service under Section 169 may require factual scrutiny, while Rule 108 governs electronic or permitted manual filing where an order is unavailable on the portal. Statutory pre-deposit triggers a deemed stay of recovery for the balance demand. Article 226 may exceptionally restore an unheard appeal where defective communication, prompt action after knowledge and material procedural unfairness justify relief, but is not a routine cure for delay or inaction.
Section 107 of the CGST Act confines GST appeals to a three-month filing period, with condonation by the Appellate Authority limited to one further month upon sufficient cause. Section 5 of the Limitation Act cannot enlarge that statutory ceiling. Limitation runs from communication; portal availability and postal service under Section 169 may require factual scrutiny, while Rule 108 governs electronic or permitted manual filing where an order is unavailable on the portal. Statutory pre-deposit triggers a deemed stay of recovery for the balance demand. Article 226 may exceptionally restore an unheard appeal where defective communication, prompt action after knowledge and material procedural unfairness justify relief, but is not a routine cure for delay or inaction.
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