Dispute Resolution Panel objections must reach both prescribed forums; otherwise assessment may proceed and statutory appeal remains the proper remedy...
Political contribution deductions require recipient party compliance with contribution-reporting conditions; banking-channel donations alone do not qu...
Aggregation under TNMM prevents selective testing of intra-group services without comparable uncontrolled transactions, while appellate additional cla...
Protective assessment cannot duplicate identical receipts under competing characterisations; remote services did not establish a taxable permanent est...
Filling of Modified return after amalgamation - Effect of order of tribunal or court in respect of business reorganisation u/s 170A - The High Court observed that Section 170A of the Income Tax Act mandates that any assessment after a business reorganization should be based on the modified return. Since the scheme of amalgamation became effective from 01.04.2020, the petitioner's consolidated return after amalgamation should have been the basis for assessment. - Consequently, the matter remanded back to AO to make a reassessment on the basis of such consolidated return of income.
Filling of Modified return after amalgamation - Effect of order of tribunal or court in respect of business reorganisation u/s 170A - The High Court observed that Section 170A of the Income Tax Act mandates that any assessment after a business reorganization should be based on the modified return. Since the scheme of amalgamation became effective from 01.04.2020, the petitioner's consolidated return after amalgamation should have been the basis for assessment. - Consequently, the matter remanded back to AO to make a reassessment on the basis of such consolidated return of income.
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