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...
A pre-existing operational debt dispute over damaged and unreturned shuttering and scaffolding material, and pending reconciliation, was held to bar initiation of insolvency proceedings. Applying Mobilox principles, the tribunal found the debtor's defence-failure to replace or value damaged goods and requests for collection and valuation-plausible and supported by contemporaneous correspondence predating the demand notice; therefore the invoices remained disputed and not admitted. The adjudicating authority was correct to reject the insolvency petition without adjudicating the merits of the defence, and the appeal against that rejection was dismissed.
A pre-existing operational debt dispute over damaged and unreturned shuttering and scaffolding material, and pending reconciliation, was held to bar initiation of insolvency proceedings. Applying Mobilox principles, the tribunal found the debtor's defence-failure to replace or value damaged goods and requests for collection and valuation-plausible and supported by contemporaneous correspondence predating the demand notice; therefore the invoices remained disputed and not admitted. The adjudicating authority was correct to reject the insolvency petition without adjudicating the merits of the defence, and the appeal against that rejection was dismissed.
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