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...
Crystallisation of statutory liabilities in CIRP requires prior statutory adjudication; claims under the provident fund law that were unadjudicated as on the insolvency commencement date are not crystallised, and their admission by the Resolution Professional for collation does not substitute adjudication, so such claims were excluded from the approved resolution plan. The moratorium prevents initiation or continuation of assessment proceedings affecting the frozen claims, and the approved resolution plan, having met CoC approval and statutory scrutiny, is final and binding; appellate interference was refused and the appeal dismissed.
Crystallisation of statutory liabilities in CIRP requires prior statutory adjudication; claims under the provident fund law that were unadjudicated as on the insolvency commencement date are not crystallised, and their admission by the Resolution Professional for collation does not substitute adjudication, so such claims were excluded from the approved resolution plan. The moratorium prevents initiation or continuation of assessment proceedings affecting the frozen claims, and the approved resolution plan, having met CoC approval and statutory scrutiny, is final and binding; appellate interference was refused and the appeal dismissed.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4918 
