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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A renewed challenge to the implementation of an approved resolution plan was barred by res judicata and constructive res judicata because the same issues had already been raised in earlier proceedings, the plan approval had attained finality, and prior appeals had failed. The NCLAT held that the appellant could not reopen its status or quantum of dues as a secured operational creditor by filing another appeal against the same common order, and its refusal to accept the plan amount was obstructing completion of the insolvency process. It also held that an approved resolution plan must be implemented unconditionally, so post-approval liabilities cannot be added or made contingent on further clarifications. The appeal and interlocutory application were dismissed, with directions for compliance.
A renewed challenge to the implementation of an approved resolution plan was barred by res judicata and constructive res judicata because the same issues had already been raised in earlier proceedings, the plan approval had attained finality, and prior appeals had failed. The NCLAT held that the appellant could not reopen its status or quantum of dues as a secured operational creditor by filing another appeal against the same common order, and its refusal to accept the plan amount was obstructing completion of the insolvency process. It also held that an approved resolution plan must be implemented unconditionally, so post-approval liabilities cannot be added or made contingent on further clarifications. The appeal and interlocutory application were dismissed, with directions for compliance.
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