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...
The amended exclusion from the interim moratorium applies to personal-guarantor insolvency applications filed before its commencement that remain pending. Its application is retroactive because it governs a continuing proceeding from the amendment's effective date without impairing vested rights, and it does not depend on the identity of the insolvency applicant. The interim moratorium consequently ceases for affected guarantors. Pending commencement and conduct of arbitration, limited protection may require asset disclosure and restrain alienation or dissipation of disclosed assets. Such measures do not require a deposit and may be vacated if arbitration-appointment proceedings are not initiated within the stipulated period, while remaining subject to modification by the arbitral tribunal.
The amended exclusion from the interim moratorium applies to personal-guarantor insolvency applications filed before its commencement that remain pending. Its application is retroactive because it governs a continuing proceeding from the amendment's effective date without impairing vested rights, and it does not depend on the identity of the insolvency applicant. The interim moratorium consequently ceases for affected guarantors. Pending commencement and conduct of arbitration, limited protection may require asset disclosure and restrain alienation or dissipation of disclosed assets. Such measures do not require a deposit and may be vacated if arbitration-appointment proceedings are not initiated within the stipulated period, while remaining subject to modification by the arbitral tribunal.
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TaxTMI 
TaxTMI 
of 4918 
