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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Rejection of Section 9 application - CIRP - cyber fraud committed against the Respondent - pre-existing disputes or not - While a cyber fraud occurred, the Tribunal noted that it did not necessarily constitute a pre-existing dispute between the parties. The fraud was committed by unknown third parties, as per the respondent's own admission in their police complaint. The Tribunal concluded that the fraud and subsequent police complaint did not establish a dispute between the appellant and respondent. - The Tribunal affirmed that the debt was undisputed and unpaid, satisfying the criteria for initiating proceedings under Section 9 of the IBC.
Rejection of Section 9 application - CIRP - cyber fraud committed against the Respondent - pre-existing disputes or not - While a cyber fraud occurred, the Tribunal noted that it did not necessarily constitute a pre-existing dispute between the parties. The fraud was committed by unknown third parties, as per the respondent's own admission in their police complaint. The Tribunal concluded that the fraud and subsequent police complaint did not establish a dispute between the appellant and respondent. - The Tribunal affirmed that the debt was undisputed and unpaid, satisfying the criteria for initiating proceedings under Section 9 of the IBC.
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