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...
For insolvency proceedings against personal guarantors, limitation runs from the demand notice invoking the guarantee and the guarantor's failure to pay within the stipulated period, not from the corporate debtor's default record. The Appellate Tribunal held that the notice dated 25.10.2019 validly invoked the personal guarantees, the relevant default date was 24.12.2019, and the Section 95 applications filed on 31.03.2022 were therefore within limitation. It also held that the absence of the revival letter with the original application was irrelevant to limitation, and that the Adjudicating Authority erred in treating the petitions as time-barred or in finding inconsistent default dates. The impugned orders were set aside and the petitions revived for fresh consideration under Section 100.
For insolvency proceedings against personal guarantors, limitation runs from the demand notice invoking the guarantee and the guarantor's failure to pay within the stipulated period, not from the corporate debtor's default record. The Appellate Tribunal held that the notice dated 25.10.2019 validly invoked the personal guarantees, the relevant default date was 24.12.2019, and the Section 95 applications filed on 31.03.2022 were therefore within limitation. It also held that the absence of the revival letter with the original application was irrelevant to limitation, and that the Adjudicating Authority erred in treating the petitions as time-barred or in finding inconsistent default dates. The impugned orders were set aside and the petitions revived for fresh consideration under Section 100.
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