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...
After transfer of the assessee's jurisdiction from Ajmer to Mumbai under section 127, the earlier Assessing Officer became functus officio and lacked authority to issue the reassessment notice or complete assessment. The Tribunal held that valid assumption of jurisdiction is a condition precedent, not a procedural irregularity, so proceedings initiated by an officer without inherent jurisdiction are void ab initio. Accordingly, the reassessment orders for both years were quashed as invalid, and the Revenue's grounds on the merits became academic and infructuous.
After transfer of the assessee's jurisdiction from Ajmer to Mumbai under section 127, the earlier Assessing Officer became functus officio and lacked authority to issue the reassessment notice or complete assessment. The Tribunal held that valid assumption of jurisdiction is a condition precedent, not a procedural irregularity, so proceedings initiated by an officer without inherent jurisdiction are void ab initio. Accordingly, the reassessment orders for both years were quashed as invalid, and the Revenue's grounds on the merits became academic and infructuous.
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