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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Assessment against company dissolved/insolvent - This case revolved around an appeal against the order of the CIT(A) by an assessee undergoing Corporate Insolvency Resolution Process under the IBC, 2016. The ITAT Kolkata dismissed the appeal as infructuous, acknowledging the ongoing CIRP and its implications on income tax proceedings. The tribunal highlighted the overriding effect of the IBC over other laws, including the Income Tax Act, and noted the binding nature of an approved resolution plan on all stakeholders, including tax authorities.
Assessment against company dissolved/insolvent - This case revolved around an appeal against the order of the CIT(A) by an assessee undergoing Corporate Insolvency Resolution Process under the IBC, 2016. The ITAT Kolkata dismissed the appeal as infructuous, acknowledging the ongoing CIRP and its implications on income tax proceedings. The tribunal highlighted the overriding effect of the IBC over other laws, including the Income Tax Act, and noted the binding nature of an approved resolution plan on all stakeholders, including tax authorities.
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