Penny-stock additions require transaction-specific evidence; general investigation material alone cannot establish undisclosed income or accommodation...
Transfer pricing comparability prioritises reliable external CUPs and foreign-currency LIBOR benchmarks for exports, borrowings and delayed receivable...
Section 153C satisfaction and seized electronic records sustained unexplained-investment addition, subject to proportionate ownership-share verificati...
Liquidation of the Corporate Debtor - SRA has not made the payments within the timeline - The tribunal noted that the impugned order was based on the premise that not proceeding with liquidation would modify the resolution plan, which it deemed impermissible under the Code. However, the tribunal observed that extending payment timelines does not inherently modify the resolution plan and thus cannot justify liquidation. - The tribunal upheld the commercial wisdom of the CoC, which had a majority vote against liquidation. It emphasized that such decisions should not be disregarded lightly by the Adjudicating Authority.
Liquidation of the Corporate Debtor - SRA has not made the payments within the timeline - The tribunal noted that the impugned order was based on the premise that not proceeding with liquidation would modify the resolution plan, which it deemed impermissible under the Code. However, the tribunal observed that extending payment timelines does not inherently modify the resolution plan and thus cannot justify liquidation. - The tribunal upheld the commercial wisdom of the CoC, which had a majority vote against liquidation. It emphasized that such decisions should not be disregarded lightly by the Adjudicating Authority.
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