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 HC upheld the impugned judgment in full and dismissed the appeal. The court found the revocation of the IPLOI (as amended) and subsequent invocation of the unconditional bank guarantee valid under the contractual terms: the Appellants defaulted, Clause 11 and the Addendum authorized termination and invocation, and the IPLOI prevailed over any RFP discrepancy. The Section 7 application filed by Respondent No.1 was not admitted before revocation and was ultimately dismissed as infructuous, so no actionable fraud was attributable to Respondent No.1; allegations of fraud were unpleaded and unproved. The court declined to restrain invocation of the unconditional BG absent egregious fraud or irretrievable injustice.
The HC upheld the impugned judgment in full and dismissed the appeal. The court found the revocation of the IPLOI (as amended) and subsequent invocation of the unconditional bank guarantee valid under the contractual terms: the Appellants defaulted, Clause 11 and the Addendum authorized termination and invocation, and the IPLOI prevailed over any RFP discrepancy. The Section 7 application filed by Respondent No.1 was not admitted before revocation and was ultimately dismissed as infructuous, so no actionable fraud was attributable to Respondent No.1; allegations of fraud were unpleaded and unproved. The court declined to restrain invocation of the unconditional BG absent egregious fraud or irretrievable injustice.
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TaxTMI 
TaxTMI 
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