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...
A pre-CIRP concession agreement that had already been terminated could not be compelled to revive through an approved resolution plan or a later implementation order, because it no longer formed part of the CIRP estate in a manner permitting such direction. The NCLAT held that the Adjudicating Authority had exceeded its permissible scope by directing the appellant, who was not a CIRP participant, to act on the plan insofar as it required revival of the agreement. The order was modified to remove any such direction, while the parties were left free to pursue conciliation or arbitration in accordance with law.
A pre-CIRP concession agreement that had already been terminated could not be compelled to revive through an approved resolution plan or a later implementation order, because it no longer formed part of the CIRP estate in a manner permitting such direction. The NCLAT held that the Adjudicating Authority had exceeded its permissible scope by directing the appellant, who was not a CIRP participant, to act on the plan insofar as it required revival of the agreement. The order was modified to remove any such direction, while the parties were left free to pursue conciliation or arbitration in accordance with law.
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