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...
Safe harbour under Rule 11UA(4) was treated as curative and retrospectively applicable: where the difference between issue price and the prescribed valuation did not exceed 10%, the issue price was deemed to be fair market value, so the section 56(2)(viib) addition on shares issued to the resident shareholder could not survive. Legal and professional charges for due diligence, business evaluation and advisory services connected with structuring and growth were held to be revenue expenditure, because no capital asset or enduring capital advantage was shown; the disallowance was deleted.
Safe harbour under Rule 11UA(4) was treated as curative and retrospectively applicable: where the difference between issue price and the prescribed valuation did not exceed 10%, the issue price was deemed to be fair market value, so the section 56(2)(viib) addition on shares issued to the resident shareholder could not survive. Legal and professional charges for due diligence, business evaluation and advisory services connected with structuring and growth were held to be revenue expenditure, because no capital asset or enduring capital advantage was shown; the disallowance was deleted.
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