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...
NCLAT allowed in part and disposed the appeal, setting aside the public notice and upholding directions for a fresh Swiss-challenge private sale with revised notice publication and reasonable EMD. The court held the applicant lacked standing to impugn the sale initially, but its grievances regarding compressed timelines, opaque Process Document and impediments to meaningful participation were well-founded; the Process Document frustrated competitive bidding and value maximization. NCLAT ruled that prior permission of the Adjudicating Authority is required for private sale under the LPR and its absence amounted to infraction, though prior approval already granted by the Adjudicating Authority cured certain defects. Allegations of collusion between the SCC member and the anchor bidder were unsupported.
NCLAT allowed in part and disposed the appeal, setting aside the public notice and upholding directions for a fresh Swiss-challenge private sale with revised notice publication and reasonable EMD. The court held the applicant lacked standing to impugn the sale initially, but its grievances regarding compressed timelines, opaque Process Document and impediments to meaningful participation were well-founded; the Process Document frustrated competitive bidding and value maximization. NCLAT ruled that prior permission of the Adjudicating Authority is required for private sale under the LPR and its absence amounted to infraction, though prior approval already granted by the Adjudicating Authority cured certain defects. Allegations of collusion between the SCC member and the anchor bidder were unsupported.
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