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...
SC held that Respondent No. 1's appeal was time-barred under Section 61(2) of the IBC. The limitation period commenced on 07.04.2022 and expired on 07.05.2022, with a maximum statutory period of 45 days. The appeal was filed on 24.05.2022, beyond the prescribed and condonable periods. The NCLAT lacks jurisdiction to condone delays beyond the statutorily defined 30+15 days period. The court emphasized the IBC's strict procedural discipline, which mandates adherence to prescribed timelines to ensure efficient resolution of insolvency proceedings. Consequently, the appeal was dismissed, reinforcing the tribunal's limited power to extend limitation periods.
SC held that Respondent No. 1's appeal was time-barred under Section 61(2) of the IBC. The limitation period commenced on 07.04.2022 and expired on 07.05.2022, with a maximum statutory period of 45 days. The appeal was filed on 24.05.2022, beyond the prescribed and condonable periods. The NCLAT lacks jurisdiction to condone delays beyond the statutorily defined 30+15 days period. The court emphasized the IBC's strict procedural discipline, which mandates adherence to prescribed timelines to ensure efficient resolution of insolvency proceedings. Consequently, the appeal was dismissed, reinforcing the tribunal's limited power to extend limitation periods.
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