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 central issue was whether initiation of CIRP under Section 7 failed because the alleged debt arose from an oral agreement. The tribunal held that documentary evidence - balance-sheet entries, interest accruals as per the cited agreement, TDS Form-16A and the respondent's own admissions recorded in the impugned order - establish existence of debt and default; therefore the oral-agreement contention is unsustainable. Consequence: the admission of the Section 7 application and initiation of CIRP is upheld and the appeal is dismissed. - NCLAT
The central issue was whether initiation of CIRP under Section 7 failed because the alleged debt arose from an oral agreement. The tribunal held that documentary evidence - balance-sheet entries, interest accruals as per the cited agreement, TDS Form-16A and the respondent's own admissions recorded in the impugned order - establish existence of debt and default; therefore the oral-agreement contention is unsustainable. Consequence: the admission of the Section 7 application and initiation of CIRP is upheld and the appeal is dismissed. - NCLAT
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TaxTMI 
TaxTMI 
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