Pre-amendment reassessment limitation bars late notices under the preserved regime, invalidating consequential reassessment for affected earlier asses...
Cash-sales explanations for bank deposits require documentary reconciliation; reassessment notice survived where effective response time was available...
Functional comparability in transfer pricing prevents ad hoc arm's length adjustments where functions, assets, risks and reliable comparables are unes...
Contingency expenses, exempt-income disallowance, and royalty benchmarking: unsupported adjustments were deleted under consistent accounting and trans...
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Timely resolution under the IBC was held to outweigh an indefinitely delayed plan approval process where the post-remand refiling timeline was missed, no extension or condonation was sought, and defects in the approval application remained unresolved for months. The Appellate Tribunal held that extension beyond the outer limit is reserved for exceptional cases where delay stems from legal proceedings or factors not attributable to the parties, which was not shown here because the delay was caused by the resolution professional and the committee of creditors. Liquidation was therefore upheld, and the challenge to the rejection of the plan failed. Adverse remarks against the resolution professional were also sustained as fact-based and supported by the record.
Timely resolution under the IBC was held to outweigh an indefinitely delayed plan approval process where the post-remand refiling timeline was missed, no extension or condonation was sought, and defects in the approval application remained unresolved for months. The Appellate Tribunal held that extension beyond the outer limit is reserved for exceptional cases where delay stems from legal proceedings or factors not attributable to the parties, which was not shown here because the delay was caused by the resolution professional and the committee of creditors. Liquidation was therefore upheld, and the challenge to the rejection of the plan failed. Adverse remarks against the resolution professional were also sustained as fact-based and supported by the record.
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