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...
Dispute concerns whether a settlement resolution applicant (SRA) qualified as a related party and thus was ineligible to submit a resolution plan. The tribunal noted the alleged transaction rested on a non-binding term sheet and no definitive contract or allotment of shares occurred, meaning the factual elements underpinning related party attribution were absent, yet the SRA was treated as a related party. The adjudicating authority previously considered and rejected the ineligibility challenge, rendering that determination final and permitting approval of the resolution plan; accordingly the appellate challenge to that approval was dismissed.
Dispute concerns whether a settlement resolution applicant (SRA) qualified as a related party and thus was ineligible to submit a resolution plan. The tribunal noted the alleged transaction rested on a non-binding term sheet and no definitive contract or allotment of shares occurred, meaning the factual elements underpinning related party attribution were absent, yet the SRA was treated as a related party. The adjudicating authority previously considered and rejected the ineligibility challenge, rendering that determination final and permitting approval of the resolution plan; accordingly the appellate challenge to that approval was dismissed.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4918 
