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 - Date of default - breach of guarantee - The application u/s 7 was filed on the basis of breach of guarantee and inability of the ‘Corporate Debtor’ to repay the outstanding dues and therefore breach of guarantee date becomes the cause of action as well as the date of default as indicated in Part IV of the Application - Application was filed within 1 months from the date of default - Hence, averments of the ‘Appellant’ that the application was barred by limitation does not succeed. - AT
Initiation of CIRP - Period of limitation - Date of default - breach of guarantee - The application u/s 7 was filed on the basis of breach of guarantee and inability of the ‘Corporate Debtor’ to repay the outstanding dues and therefore breach of guarantee date becomes the cause of action as well as the date of default as indicated in Part IV of the Application - Application was filed within 1 months from the date of default - Hence, averments of the ‘Appellant’ that the application was barred by limitation does not succeed. - AT
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