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...
Approved resolution plans extinguish pre-approval statutory dues that were not claimed in the corporate insolvency resolution process and do not form part of the plan. Applying the clean slate principle, the Appellate Tribunal held that unclaimed Income Tax Department dues and other statutory dues existing on the date of approval could not survive against the successful resolution applicant. It also distinguished extinguishment of past dues from affirmative tax relief: any concession, waiver or relief under the Income Tax Act still requires approach to the competent authority, and that condition was upheld.
Approved resolution plans extinguish pre-approval statutory dues that were not claimed in the corporate insolvency resolution process and do not form part of the plan. Applying the clean slate principle, the Appellate Tribunal held that unclaimed Income Tax Department dues and other statutory dues existing on the date of approval could not survive against the successful resolution applicant. It also distinguished extinguishment of past dues from affirmative tax relief: any concession, waiver or relief under the Income Tax Act still requires approach to the competent authority, and that condition was upheld.
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