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 post-submission addendum that sought to improve the financial proposal and scoring under the evaluation matrix was treated as an impermissible modification of a final resolution plan, so the CoC validly rejected it. The Tribunal held that commercial wisdom governed evaluation of competing plans, the process note did not require acceptance of the highest NPV or highest score, and the RP's email did not amount to material irregularity. It further held that the approved resolution plan met the Code and CIRP Regulations, leaving no permissible ground for judicial interference with the CoC's decision or the approval order.
A post-submission addendum that sought to improve the financial proposal and scoring under the evaluation matrix was treated as an impermissible modification of a final resolution plan, so the CoC validly rejected it. The Tribunal held that commercial wisdom governed evaluation of competing plans, the process note did not require acceptance of the highest NPV or highest score, and the RP's email did not amount to material irregularity. It further held that the approved resolution plan met the Code and CIRP Regulations, leaving no permissible ground for judicial interference with the CoC's decision or the approval order.
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