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...
SC held that interim moratorium under Section 96 IBC does not protect against criminal prosecution under Section 138 of NI Act. The moratorium is restricted to civil claims for debt recovery and does not extend to criminal proceedings. The protection applies only to corporate debtors, not personal guarantors or individual directors. Prosecutorial actions for cheque dishonor remain valid, as the legislative intent is to maintain commercial transaction integrity. The court emphasized that criminal liability cannot be evaded through insolvency proceedings. Consequently, the appellants' petition seeking stay of criminal proceedings was dismissed, reinforcing the deterrent effect of the NI Act in ensuring accountability in commercial transactions.
SC held that interim moratorium under Section 96 IBC does not protect against criminal prosecution under Section 138 of NI Act. The moratorium is restricted to civil claims for debt recovery and does not extend to criminal proceedings. The protection applies only to corporate debtors, not personal guarantors or individual directors. Prosecutorial actions for cheque dishonor remain valid, as the legislative intent is to maintain commercial transaction integrity. The court emphasized that criminal liability cannot be evaded through insolvency proceedings. Consequently, the appellants' petition seeking stay of criminal proceedings was dismissed, reinforcing the deterrent effect of the NI Act in ensuring accountability in commercial transactions.
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