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 ITAT treated the alleged double addition in income computation, including the set-off of brought forward losses and unabsorbed depreciation, as a connected computational error and remitted the matter for fresh adjudication after hearing the assessee. It also found the transfer pricing adjustment unsustainable because the retained comparables were functionally and product-wise dissimilar to the assessee's manufacturing activity, and held that the assessee's proposed comparables and depreciation policies had to be considered. The transfer pricing issue was likewise set aside and restored to the AO for reconsideration in accordance with law. The appeal was thus allowed for statistical purposes.
The ITAT treated the alleged double addition in income computation, including the set-off of brought forward losses and unabsorbed depreciation, as a connected computational error and remitted the matter for fresh adjudication after hearing the assessee. It also found the transfer pricing adjustment unsustainable because the retained comparables were functionally and product-wise dissimilar to the assessee's manufacturing activity, and held that the assessee's proposed comparables and depreciation policies had to be considered. The transfer pricing issue was likewise set aside and restored to the AO for reconsideration in accordance with law. The appeal was thus allowed for statistical purposes.
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