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...
Interference with an approved resolution plan under the Insolvency and Bankruptcy Code is confined to patent illegality, material irregularity, violation of mandatory law, or perversity, and a completed insolvency process cannot be reopened for mere dissatisfaction with claim treatment. The appellant's claim remained disputed and contingent throughout verification because of reciprocal contractual claims and counter-claims, so there was no admitted operational debt and no basis for invoking notice rights under Section 24(3)(c). Allegations of fraud, suppression, and procedural impropriety were unsupported, and the appellant showed no material prejudice affecting the resolution outcome. The appeal was dismissed, and the approved and implemented plan was left undisturbed.
Interference with an approved resolution plan under the Insolvency and Bankruptcy Code is confined to patent illegality, material irregularity, violation of mandatory law, or perversity, and a completed insolvency process cannot be reopened for mere dissatisfaction with claim treatment. The appellant's claim remained disputed and contingent throughout verification because of reciprocal contractual claims and counter-claims, so there was no admitted operational debt and no basis for invoking notice rights under Section 24(3)(c). Allegations of fraud, suppression, and procedural impropriety were unsupported, and the appellant showed no material prejudice affecting the resolution outcome. The appeal was dismissed, and the approved and implemented plan was left undisturbed.
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TaxTMI 
TaxTMI 
of 4918 
