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...
Dismissal of Section 9 application - pre-existing dispute - The Tribunal examined the evidence, including email correspondences, and concluded that a debtor-creditor relationship existed between the parties. Moreover, the Tribunal found that there was a genuine pre-existing dispute regarding the alleged debt, which precluded the application of the Insolvency and Bankruptcy Code. As a result, the Tribunal upheld the decision of the Adjudicating Authority to dismiss the petition.
Dismissal of Section 9 application - pre-existing dispute - The Tribunal examined the evidence, including email correspondences, and concluded that a debtor-creditor relationship existed between the parties. Moreover, the Tribunal found that there was a genuine pre-existing dispute regarding the alleged debt, which precluded the application of the Insolvency and Bankruptcy Code. As a result, the Tribunal upheld the decision of the Adjudicating Authority to dismiss the petition.
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TaxTMI 
TaxTMI 
of 4918 
