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...
NCLAT applied a justice-oriented reading of sufficient cause and condoned a seven-day delay in filing the appeal, accepting that non-communication by earlier counsel and prompt action after learning of the order justified relief. It also treated closure of the right to file reply in Section 9 insolvency proceedings as subject to natural justice and a fair opportunity to defend; where the proposed defence was prima facie substantial and no deliberate negligence was shown, denial of reply would not advance justice. The closure order was set aside, one final opportunity to file the reply was granted, and the merits were left open.
NCLAT applied a justice-oriented reading of sufficient cause and condoned a seven-day delay in filing the appeal, accepting that non-communication by earlier counsel and prompt action after learning of the order justified relief. It also treated closure of the right to file reply in Section 9 insolvency proceedings as subject to natural justice and a fair opportunity to defend; where the proposed defence was prima facie substantial and no deliberate negligence was shown, denial of reply would not advance justice. The closure order was set aside, one final opportunity to file the reply was granted, and the merits were left open.
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