Penny-stock additions require transaction-specific evidence; general investigation material alone cannot establish undisclosed income or accommodation...
Transfer pricing comparability prioritises reliable external CUPs and foreign-currency LIBOR benchmarks for exports, borrowings and delayed receivable...
Section 153C satisfaction and seized electronic records sustained unexplained-investment addition, subject to proportionate ownership-share verificati...
A Section 7 application was rejected as time-barred, raising issues whether the claimant was a financial creditor and whether the claim was within limitation. The underlying contract treated the trade advance as converting into a debt carrying time value of money upon default, satisfying the statutory elements of "financial debt"; consequently, the claimant was correctly classified as a financial creditor. On limitation, the exclusion/extension period directed in the SC suo motu proceedings required adding the balance limitation from 15.03.2020 to 01.03.2022, rendering the filing within time; therefore, the rejection on limitation was unsustainable and the appeal was allowed. - NCLAT
A Section 7 application was rejected as time-barred, raising issues whether the claimant was a financial creditor and whether the claim was within limitation. The underlying contract treated the trade advance as converting into a debt carrying time value of money upon default, satisfying the statutory elements of "financial debt"; consequently, the claimant was correctly classified as a financial creditor. On limitation, the exclusion/extension period directed in the SC suo motu proceedings required adding the balance limitation from 15.03.2020 to 01.03.2022, rendering the filing within time; therefore, the rejection on limitation was unsustainable and the appeal was allowed. - NCLAT
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