Third-party loose sheets require reliable nexus before supporting unexplained expenditure additions; presumptions do not establish payer identity or o...
TNMM comparability using audited accounts and working-capital adjustments can eliminate unwarranted transfer-pricing additions where verified margins ...
Gross-profit additions on disputed purchases require reasoned appellate determination; disclosed claims alone do not support inaccurate-particulars pe...
Limitation after transfer-pricing remand: fresh TPO reference did not extend the assessment deadline, rendering the consequential assessment time-barr...
Interim judicial restraint on tax deduction prevents default, while supporting reasonable cause and penalty deletion for foreign-leg LFC reimbursement...
Palmolein classification defeated the crude-oil concession; material misdeclaration sustained recovery and confiscation, while separate false-document...
Individual shareholders do not, merely by virtue of shareholding, qualify as aggrieved persons entitled to appeal approval of a corporate debtor's resolution plan. Allegations that post-approval modifications were fraudulent cannot expand standing unless supported by specific material. Homebuyers who have not independently challenged the resolution plan cannot contest it indirectly by supporting a shareholder's appeal. The shareholder's challenge to the approved resolution plan was therefore treated as not maintainable, and the related interlocutory applications were rejected.
Individual shareholders do not, merely by virtue of shareholding, qualify as aggrieved persons entitled to appeal approval of a corporate debtor's resolution plan. Allegations that post-approval modifications were fraudulent cannot expand standing unless supported by specific material. Homebuyers who have not independently challenged the resolution plan cannot contest it indirectly by supporting a shareholder's appeal. The shareholder's challenge to the approved resolution plan was therefore treated as not maintainable, and the related interlocutory applications were rejected.
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