Business reorganisation requires recognition of successor's modified return; draft orders against dissolved transferor quashed and fresh review direct...
Pre-commencement R&D deduction denied where business had not commenced; deeming benefit requires tangible start of manufacture or commercial exploitat...
Priority of set-off: brought forward business losses must be adjusted before unabsorbed depreciation; procedural safeguards required for invoking rest...
The Tribunal held that the statutory one-month timeline under section 148A(d) remains mandatory and is not extended by the broader surviving-period principle under section 148; the orders for AYs 2013-14 and 2014-15 were therefore time-barred and the consequential reassessment notices and orders were quashed. It further held that where action was founded solely on third-party search material, sections 153A/153C constituted the special route and general reassessment or assessment provisions could not be invoked without the required satisfaction note; the proceedings for AYs 2013-14, 2014-15 and 2020-21 were quashed on that ground. On merits, additions for accommodation entries, bank credits and duplicate loan credits were deleted because the sales and receipts were supported by records, bank statements are not books of account, and no objective inquiry or cash trail was shown.
The Tribunal held that the statutory one-month timeline under section 148A(d) remains mandatory and is not extended by the broader surviving-period principle under section 148; the orders for AYs 2013-14 and 2014-15 were therefore time-barred and the consequential reassessment notices and orders were quashed. It further held that where action was founded solely on third-party search material, sections 153A/153C constituted the special route and general reassessment or assessment provisions could not be invoked without the required satisfaction note; the proceedings for AYs 2013-14, 2014-15 and 2020-21 were quashed on that ground. On merits, additions for accommodation entries, bank credits and duplicate loan credits were deleted because the sales and receipts were supported by records, bank statements are not books of account, and no objective inquiry or cash trail was shown.
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