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...
Proceedings under section 153C were held without jurisdiction for A.Y. 2014-15 because the satisfaction note dated 31.05.2023 fixed A.Y. 2024-25 as the reckoning year, so the ten-year block could reach back only to A.Y. 2015-16 and not earlier; the notice and assessment for A.Y. 2014-15 were quashed. For A.Ys. 2015-16 and 2016-17, the Tribunal held that satisfaction recorded after 01.04.2021 could not sustain section 153C action against the other person, and proceedings ought to have been initiated under section 148 instead; the section 153C proceedings were quashed and the remaining grounds were left academic.
Proceedings under section 153C were held without jurisdiction for A.Y. 2014-15 because the satisfaction note dated 31.05.2023 fixed A.Y. 2024-25 as the reckoning year, so the ten-year block could reach back only to A.Y. 2015-16 and not earlier; the notice and assessment for A.Y. 2014-15 were quashed. For A.Ys. 2015-16 and 2016-17, the Tribunal held that satisfaction recorded after 01.04.2021 could not sustain section 153C action against the other person, and proceedings ought to have been initiated under section 148 instead; the section 153C proceedings were quashed and the remaining grounds were left academic.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4817 
Join Channel 
