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...
The Appellate Tribunal dismissed the appeal filed by the Operational Creditor u/s 9 of the Insolvency and Bankruptcy Code, 2016. The application was initially rejected by the NCLT on the grounds of a pre-existing dispute regarding the issuance of a No Objection Certificate (NOC) by the Operational Creditor to the Corporate Debtor for registering the copyright of a TVC. The Terms and Conditions stipulated that the Operational Creditor would provide the necessary NOC for IP registration, which it failed to do despite repeated demands from the Corporate Debtor. The dispute was genuine, supported by evidence, and arose before the issuance of the Section 8 notice, qualifying as a "pre-existing dispute" - a valid ground for rejecting the Section 9 application. The Appellate Tribunal upheld the NCLT's order, finding no merit in the appeal.
The Appellate Tribunal dismissed the appeal filed by the Operational Creditor u/s 9 of the Insolvency and Bankruptcy Code, 2016. The application was initially rejected by the NCLT on the grounds of a pre-existing dispute regarding the issuance of a No Objection Certificate (NOC) by the Operational Creditor to the Corporate Debtor for registering the copyright of a TVC. The Terms and Conditions stipulated that the Operational Creditor would provide the necessary NOC for IP registration, which it failed to do despite repeated demands from the Corporate Debtor. The dispute was genuine, supported by evidence, and arose before the issuance of the Section 8 notice, qualifying as a "pre-existing dispute" - a valid ground for rejecting the Section 9 application. The Appellate Tribunal upheld the NCLT's order, finding no merit in the appeal.
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