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 SC affirmed the arbitral tribunal's inherent power to implead or join non-signatories to arbitration proceedings based on the 'group of companies' doctrine. The tribunal is deemed the most appropriate forum to determine whether a non-signatory is bound by an arbitration agreement, given its ability to comprehensively assess evidence and circumstances. The court emphasized that the jurisdiction of an arbitral tribunal stems from the arbitration agreement itself, and there are no statutory prohibitions preventing the tribunal from impleading a non-signatory. The appeal was ultimately dismissed, with the court highlighting the need for legislative clarity in arbitration law to reduce uncertainty in commercial disputes.
The SC affirmed the arbitral tribunal's inherent power to implead or join non-signatories to arbitration proceedings based on the 'group of companies' doctrine. The tribunal is deemed the most appropriate forum to determine whether a non-signatory is bound by an arbitration agreement, given its ability to comprehensively assess evidence and circumstances. The court emphasized that the jurisdiction of an arbitral tribunal stems from the arbitration agreement itself, and there are no statutory prohibitions preventing the tribunal from impleading a non-signatory. The appeal was ultimately dismissed, with the court highlighting the need for legislative clarity in arbitration law to reduce uncertainty in commercial disputes.
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