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...
Validity of reassessment notices under sections 148 and 148A was not examined on merits because the HC followed the Supreme Court's approach in an identical matter after insertion of section 147A. The writ appeals were allowed, the Single Judge's orders were set aside, and the matters were remitted for fresh consideration. The assessees were given liberty to amend the writ petitions to challenge section 147A and any connected or consequential provision, with all rival contentions left open for decision on remand.
Validity of reassessment notices under sections 148 and 148A was not examined on merits because the HC followed the Supreme Court's approach in an identical matter after insertion of section 147A. The writ appeals were allowed, the Single Judge's orders were set aside, and the matters were remitted for fresh consideration. The assessees were given liberty to amend the writ petitions to challenge section 147A and any connected or consequential provision, with all rival contentions left open for decision on remand.
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