Commitment proceedings gain extended timelines, structured defect refiling, and automatic resumption of inquiry after the adjusted completion period e...
Centralised assessment transfer becomes unwarranted once the searched person's assessment is complete, requiring restoration to the appropriate charge...
Co-operative deduction eligibility excludes refund and commercial-bank interest, while qualifying co-operative investments require entity-wise verific...
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A company sold as a going concern in liquidation was treated as acquired on a clean slate basis, so past liabilities and investigations stood extinguished under the insolvency framework. The High Court applied the settled principle from insolvency sale jurisprudence and held that reopening could not proceed on that footing. It also found the reassessment to be based on an unverified assumption that interest deduction might have been claimed, despite the company's explanation that no such deduction was taken and the matter was verifiable from the accounts. As the AO acted on surmises rather than examined material, the notice and the order under Section 148A(d) were quashed.
A company sold as a going concern in liquidation was treated as acquired on a clean slate basis, so past liabilities and investigations stood extinguished under the insolvency framework. The High Court applied the settled principle from insolvency sale jurisprudence and held that reopening could not proceed on that footing. It also found the reassessment to be based on an unverified assumption that interest deduction might have been claimed, despite the company's explanation that no such deduction was taken and the matter was verifiable from the accounts. As the AO acted on surmises rather than examined material, the notice and the order under Section 148A(d) were quashed.
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