Third-party loose sheets require reliable nexus before supporting unexplained expenditure additions; presumptions do not establish payer identity or o...
TNMM comparability using audited accounts and working-capital adjustments can eliminate unwarranted transfer-pricing additions where verified margins ...
Gross-profit additions on disputed purchases require reasoned appellate determination; disclosed claims alone do not support inaccurate-particulars pe...
Limitation after transfer-pricing remand: fresh TPO reference did not extend the assessment deadline, rendering the consequential assessment time-barr...
Interim judicial restraint on tax deduction prevents default, while supporting reasonable cause and penalty deletion for foreign-leg LFC reimbursement...
Palmolein classification defeated the crude-oil concession; material misdeclaration sustained recovery and confiscation, while separate false-document...
Insolvency and BankruptcyApril 16, 2024Case LawsAT
CIRP - Corporate Guarantee and Liability - The Appellate Tribunal acknowledged that the company had issued corporate guarantees to financial institutions. Despite the guarantee not being invoked, the Tribunal emphasized that the liability of the corporate guarantor remains intact. It cited clauses from the Guarantee Deed emphasizing that the rights of lenders against the guarantor remain in force regardless of any arrangements between lenders and other guarantors.
CIRP - Corporate Guarantee and Liability - The Appellate Tribunal acknowledged that the company had issued corporate guarantees to financial institutions. Despite the guarantee not being invoked, the Tribunal emphasized that the liability of the corporate guarantor remains intact. It cited clauses from the Guarantee Deed emphasizing that the rights of lenders against the guarantor remain in force regardless of any arrangements between lenders and other guarantors.
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