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...
Ad hoc restriction of employee benefit expenditure requires reconciliation of salary details, vouchers, service evidence and business nexus, rather than comparison with revenue alone. Share premium additions turn on substantiation of fair market value under the valuation framework, and an incorrect statutory label does not displace the substance of the addition where no valuation report is produced. ESOP discount is recognised as employee compensation and potentially allowable as business expenditure, but the claim must be supported by valuation and grant-wise working. Loss on sale of subsidiary investment may be treated as business loss only where commercial expediency is established, and additional evidence must comply with Rule 46A and natural justice.
Ad hoc restriction of employee benefit expenditure requires reconciliation of salary details, vouchers, service evidence and business nexus, rather than comparison with revenue alone. Share premium additions turn on substantiation of fair market value under the valuation framework, and an incorrect statutory label does not displace the substance of the addition where no valuation report is produced. ESOP discount is recognised as employee compensation and potentially allowable as business expenditure, but the claim must be supported by valuation and grant-wise working. Loss on sale of subsidiary investment may be treated as business loss only where commercial expediency is established, and additional evidence must comply with Rule 46A and natural justice.
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