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...
NCLAT determined the time limitation for filing a company petition. The Respondent filed the petition on 12.08.2021, which was within the prescribed limitation period, considering multiple one-time settlement (OTS) letters extending the timeline and the Supreme Court's suo moto order extending limitation from 15.03.2020 to 28.02.2022. Despite multiple opportunities, the Appellant failed to contest the Respondent's submissions or provide contrary evidence. The Tribunal noted that limitation is a matter of both fact and law, which can be invoked at any stage. Relying on precedent, the Tribunal found no merit in the Appellant's challenge, consequently dismissing the appeal.
NCLAT determined the time limitation for filing a company petition. The Respondent filed the petition on 12.08.2021, which was within the prescribed limitation period, considering multiple one-time settlement (OTS) letters extending the timeline and the Supreme Court's suo moto order extending limitation from 15.03.2020 to 28.02.2022. Despite multiple opportunities, the Appellant failed to contest the Respondent's submissions or provide contrary evidence. The Tribunal noted that limitation is a matter of both fact and law, which can be invoked at any stage. Relying on precedent, the Tribunal found no merit in the Appellant's challenge, consequently dismissing the appeal.
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TaxTMI 
TaxTMI 
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