Reopening of assessment cannot rest solely on an audit party's opinion; reassessment under Section 147/148 is impermissible and power of revision shou...
Tested party selection: functional analysis identified the least complex unit as the appropriate tested party, altering the transfer pricing adjustmen...
A 90-day extension to implement a bona fide settlement agreement was granted to the corporate debtor to enable payment of the balance sum, modifying the earlier limited protection period; if payment occurs within that period the prior withdrawal of CIRP will become operative and the CIRP will terminate. The adjudicating authority's restoration of CIRP and interim restraint on coercive steps to permit implementation was recognised but the implementation period was extended. The financial creditor and the resolution professional are directed to provide necessary assistance to facilitate implementation and payment during the granted period to further rehabilitation objectives under the Code.
A 90-day extension to implement a bona fide settlement agreement was granted to the corporate debtor to enable payment of the balance sum, modifying the earlier limited protection period; if payment occurs within that period the prior withdrawal of CIRP will become operative and the CIRP will terminate. The adjudicating authority's restoration of CIRP and interim restraint on coercive steps to permit implementation was recognised but the implementation period was extended. The financial creditor and the resolution professional are directed to provide necessary assistance to facilitate implementation and payment during the granted period to further rehabilitation objectives under the Code.
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