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 High Court noted that the Supreme Court, in identical reassessment matters, had set aside earlier quashing orders and remitted the cases for fresh consideration while keeping all merits issues open. In light of that binding development, the Court declined to examine the controversy on merits, set aside the Single Judge's order, and remitted the matter for reconsideration with all contentions preserved. The Court also granted the assessee liberty to challenge newly inserted section 147A and any connected or consequential provisions, consistent with the Supreme Court's permission in similar matters, and allowed the Revenue to file further affidavit or submissions.
The High Court noted that the Supreme Court, in identical reassessment matters, had set aside earlier quashing orders and remitted the cases for fresh consideration while keeping all merits issues open. In light of that binding development, the Court declined to examine the controversy on merits, set aside the Single Judge's order, and remitted the matter for reconsideration with all contentions preserved. The Court also granted the assessee liberty to challenge newly inserted section 147A and any connected or consequential provisions, consistent with the Supreme Court's permission in similar matters, and allowed the Revenue to file further affidavit or submissions.
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