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...
Insolvency and BankruptcyFebruary 27, 2021Case LawsAT
Initiation of CIRP by Operational Creditors - the Appellant has not fulfilled any of the conditions enumerated in Sub-Section 2 of Section 14 of the Limitation Act - thus it is not correct to accept the contention of the Appellant that the winding-up petition No.6 of 2015 was dismissed on the ground of mis-joinder of parties, and the benefit of Section 14 of the Limitation Act, 1963 cannot be allowed to appellant. - Relaxation under Section 5 of the Limitation Act, 1963 cannot be allowed for unexplained period of about two years and ten months. - AT
Initiation of CIRP by Operational Creditors - the Appellant has not fulfilled any of the conditions enumerated in Sub-Section 2 of Section 14 of the Limitation Act - thus it is not correct to accept the contention of the Appellant that the winding-up petition No.6 of 2015 was dismissed on the ground of mis-joinder of parties, and the benefit of Section 14 of the Limitation Act, 1963 cannot be allowed to appellant. - Relaxation under Section 5 of the Limitation Act, 1963 cannot be allowed for unexplained period of about two years and ten months. - AT
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