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...
Prior appellate adjudication had already conclusively rejected inclusion of the foreign oil and gas assets in the CIRP of Videocon Industries Ltd, so the later order directing inclusion could not stand. The Tribunal also held that a holding company and its subsidiary remain separate legal persons, and that co-extensive guarantor liability does not permit importing a subsidiary's assets into the guarantor's CIRP. On the resolution plan challenge, it accepted that pre-existing contractual rights, including a right of first refusal, could be respected because an approved plan must be implementable and the Committee of Creditors could, in its commercial wisdom, pursue a feasible value-maximising structure. The order approving consummation of the BPRL transaction was upheld.
Prior appellate adjudication had already conclusively rejected inclusion of the foreign oil and gas assets in the CIRP of Videocon Industries Ltd, so the later order directing inclusion could not stand. The Tribunal also held that a holding company and its subsidiary remain separate legal persons, and that co-extensive guarantor liability does not permit importing a subsidiary's assets into the guarantor's CIRP. On the resolution plan challenge, it accepted that pre-existing contractual rights, including a right of first refusal, could be respected because an approved plan must be implementable and the Committee of Creditors could, in its commercial wisdom, pursue a feasible value-maximising structure. The order approving consummation of the BPRL transaction was upheld.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4921 
