Modified returns after business reorganisations cannot trigger fresh scrutiny once the original assessment was complete, invalidating related transfer...
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...
Unilateral cancellation of an irrevocable joint development agreement and power of attorney was treated prima facie as ineffective where they conferred development rights on the corporate debtor and barred unilateral revocation. The construction period ran from requisite approvals and had been extended, while an alleged no-objection remained conditional and unaccepted. Land subject to mortgage and possible third-party rights was not excluded from the corporate insolvency resolution process at this stage. The landowner could intervene, and all parties were required to maintain status quo pending disposal of the appeal.
Unilateral cancellation of an irrevocable joint development agreement and power of attorney was treated prima facie as ineffective where they conferred development rights on the corporate debtor and barred unilateral revocation. The construction period ran from requisite approvals and had been extended, while an alleged no-objection remained conditional and unaccepted. Land subject to mortgage and possible third-party rights was not excluded from the corporate insolvency resolution process at this stage. The landowner could intervene, and all parties were required to maintain status quo pending disposal of the appeal.
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