Penny-stock additions require transaction-specific evidence; general investigation material alone cannot establish undisclosed income or accommodation...
Transfer pricing comparability prioritises reliable external CUPs and foreign-currency LIBOR benchmarks for exports, borrowings and delayed receivable...
Section 153C satisfaction and seized electronic records sustained unexplained-investment addition, subject to proportionate ownership-share verificati...
Personal guarantees were validly invoked where the demand notice was expressly addressed to the guarantors, referred to their security for the financial assistance, and called for payment of the outstanding liability. The earlier guarantee remained operative as a continuing guarantee after restructuring, as the later restructuring documents did not displace it and the borrower's restructured repayment was not honoured. The corporate debtor's CIRP moratorium did not bar action against personal guarantors, since the statutory protection does not extend to sureties under a contract of guarantee. Limitation for the Section 95 application was saved by repeated acknowledgments in balance sheets and by the recovery certificate. The appeals were dismissed.
Personal guarantees were validly invoked where the demand notice was expressly addressed to the guarantors, referred to their security for the financial assistance, and called for payment of the outstanding liability. The earlier guarantee remained operative as a continuing guarantee after restructuring, as the later restructuring documents did not displace it and the borrower's restructured repayment was not honoured. The corporate debtor's CIRP moratorium did not bar action against personal guarantors, since the statutory protection does not extend to sureties under a contract of guarantee. Limitation for the Section 95 application was saved by repeated acknowledgments in balance sheets and by the recovery certificate. The appeals were dismissed.
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