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...
Initiation of CIRP - Period of limitation -acknowledgement of debts in the Balance Sheet - the acknowledgement in Balance Sheet for FY 2016-17, relied upon by the Financial Creditor, is unequivocal and crystallizes the issue of ‘acknowledgement of debt’ as defined under Section 18 of the Limitation Act, 1963 - this Tribunal is of the earnest view that the Application filed under Section 7 of the Code is well within the period of Limitation. - AT
Initiation of CIRP - Period of limitation -acknowledgement of debts in the Balance Sheet - the acknowledgement in Balance Sheet for FY 2016-17, relied upon by the Financial Creditor, is unequivocal and crystallizes the issue of ‘acknowledgement of debt’ as defined under Section 18 of the Limitation Act, 1963 - this Tribunal is of the earnest view that the Application filed under Section 7 of the Code is well within the period of Limitation. - AT
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