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...
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A later company petition was barred by res judicata where it sought substantially the same reliefs on the same cause of action as an earlier petition, including challenge to board resolutions, restoration of position in the company and control over bank operations. The Appellate Tribunal held that the earlier orders had attained finality because they were carried through the appellate process and left undisturbed, and withdrawal of the civil appeal before the Supreme Court did not permit reopening the concluded dispute. The fresh proceeding was therefore an abuse of process and the company appeal was dismissed.
A later company petition was barred by res judicata where it sought substantially the same reliefs on the same cause of action as an earlier petition, including challenge to board resolutions, restoration of position in the company and control over bank operations. The Appellate Tribunal held that the earlier orders had attained finality because they were carried through the appellate process and left undisturbed, and withdrawal of the civil appeal before the Supreme Court did not permit reopening the concluded dispute. The fresh proceeding was therefore an abuse of process and the company appeal was dismissed.
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