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...
Reassessment initiated on a mistaken factual premise and without a live nexus to incriminating material was held unsustainable, as the record did not link the assessee to the seized third-party material and the jurisdictional approval objection was unrebutted. The Tribunal also found that approval under the reassessment provisions had not been shown to be validly obtained and that the sanction was mechanical, so the reassessment order was quashed. On the alleged on-money addition, unexplained reliance on un-confronted Excel entries and third-party statements could not displace the assessee's banking records and other documents, and the section 69 addition was deleted.
Reassessment initiated on a mistaken factual premise and without a live nexus to incriminating material was held unsustainable, as the record did not link the assessee to the seized third-party material and the jurisdictional approval objection was unrebutted. The Tribunal also found that approval under the reassessment provisions had not been shown to be validly obtained and that the sanction was mechanical, so the reassessment order was quashed. On the alleged on-money addition, unexplained reliance on un-confronted Excel entries and third-party statements could not displace the assessee's banking records and other documents, and the section 69 addition was deleted.
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