Revisionary jurisdiction under section 263 upheld; faceless assessments subject to revision when AO fails requisite enquiries, remitted for fresh asse...
Limited scope of processing under section 143(1): enhancement without show cause is unsustainable; remand for residency, taxation and TDS verification...
Completed liquidation and sale of a corporate debtor as a going concern can make income-tax appeals on pre-IBC additions infructuous where the liquidation has closed and subsisting NCLT directions require pre-transfer liabilities to be dealt with only within the IBC framework. Because assessments, notices and proceedings for the pre-transfer period were barred against the transferred entity and its successors, the Tribunal treated any merits adjudication as academic and disposed of the appeals without examining the additions. The note also clarifies that the outcome was confined to the corporate debtor and did not decide any independent action against former management or other persons.
Completed liquidation and sale of a corporate debtor as a going concern can make income-tax appeals on pre-IBC additions infructuous where the liquidation has closed and subsisting NCLT directions require pre-transfer liabilities to be dealt with only within the IBC framework. Because assessments, notices and proceedings for the pre-transfer period were barred against the transferred entity and its successors, the Tribunal treated any merits adjudication as academic and disposed of the appeals without examining the additions. The note also clarifies that the outcome was confined to the corporate debtor and did not decide any independent action against former management or other persons.
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