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 High Court held that the writ petition challenging the respondent Bank's actions in not releasing amounts deposited in an Escrow Account for payment of statutory liabilities like GST from 2017 onwards is maintainable, despite other disputes being adjudicated before the Debts Recovery Tribunal. The Bank's adjustments to the receivables in the Escrow Account for loan repayment, resulting in non-compliance with statutory requirements like filing GSTR-3B and non-payment of GST, constituted a breach of the Escrow Agreement. The petitioner Company did not have control or the right to operate the Escrow Account, which was to be operated by the respondent Bank as per the Agreement. Consequently, the writ petition was allowed.
The High Court held that the writ petition challenging the respondent Bank's actions in not releasing amounts deposited in an Escrow Account for payment of statutory liabilities like GST from 2017 onwards is maintainable, despite other disputes being adjudicated before the Debts Recovery Tribunal. The Bank's adjustments to the receivables in the Escrow Account for loan repayment, resulting in non-compliance with statutory requirements like filing GSTR-3B and non-payment of GST, constituted a breach of the Escrow Agreement. The petitioner Company did not have control or the right to operate the Escrow Account, which was to be operated by the respondent Bank as per the Agreement. Consequently, the writ petition was allowed.
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TaxTMI 
TaxTMI 
of 4921 
