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...
Corporate veil lifting for real estate project resolution treated the developer and the land-owning special purpose company as a single economic entity, bringing the leasehold land within the restored resolution plan. Allottee claims arising from the same project were addressed through completion and delivery under that plan, leaving no independently due debt to support a separate insolvency process. A parallel CIRP over the project land would impose a moratorium and vest management in an insolvency professional, obstructing implementation of the restored plan. The Monitoring Committee responsible for plan implementation had standing as an aggrieved person, and binding Supreme Court precedent required consideration. Allottees' remedy lay in enforcing the restored plan.
Corporate veil lifting for real estate project resolution treated the developer and the land-owning special purpose company as a single economic entity, bringing the leasehold land within the restored resolution plan. Allottee claims arising from the same project were addressed through completion and delivery under that plan, leaving no independently due debt to support a separate insolvency process. A parallel CIRP over the project land would impose a moratorium and vest management in an insolvency professional, obstructing implementation of the restored plan. The Monitoring Committee responsible for plan implementation had standing as an aggrieved person, and binding Supreme Court precedent required consideration. Allottees' remedy lay in enforcing the restored plan.
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