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...
An assessment made as a consequential order under the revision mechanism does not survive once the underlying revision orders are set aside and remitted for fresh consideration. Here, the Tribunal held that the assessment passed under sections 147, 263 and 144B depended entirely on section 263 orders that had already been sent back to the Principal Commissioner for a fresh order. Because that foundation had ceased to exist, the assessment order and the appellate order affirming it were treated as infructuous, and the appeals were dismissed on that basis.
An assessment made as a consequential order under the revision mechanism does not survive once the underlying revision orders are set aside and remitted for fresh consideration. Here, the Tribunal held that the assessment passed under sections 147, 263 and 144B depended entirely on section 263 orders that had already been sent back to the Principal Commissioner for a fresh order. Because that foundation had ceased to exist, the assessment order and the appellate order affirming it were treated as infructuous, and the appeals were dismissed on that basis.
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