Concessional corporate tax option under section 115BAA survives procedural documentary lapses when statutory compliance and earlier exercise are estab...
Penny-stock additions require transaction-specific evidence; general investigation material alone cannot establish undisclosed income or accommodation...
Transfer pricing comparability prioritises reliable external CUPs and foreign-currency LIBOR benchmarks for exports, borrowings and delayed receivable...
Section 153C satisfaction and seized electronic records sustained unexplained-investment addition, subject to proportionate ownership-share verificati...
Doctrine of merger inapplicable. Cancellation of petitioner's registration without assigning reasons violates principles of natural justice. Reasons form heart and soul of judicial and administrative orders, absence renders order unjustified. Despite dismissal of appeal on ground of delay, doctrine of merger has no application considering facts. Rule 23 mandates service of notice to provide opportunity for revocation application, preventing permanent cancellation and business impediment. Coordinate Bench held that once returns accepted and no dues remain, Department should not obstruct business. Order cancelling registration quashed, petitioner directed to file reply to show cause notice within three weeks. Petition allowed.
Doctrine of merger inapplicable. Cancellation of petitioner's registration without assigning reasons violates principles of natural justice. Reasons form heart and soul of judicial and administrative orders, absence renders order unjustified. Despite dismissal of appeal on ground of delay, doctrine of merger has no application considering facts. Rule 23 mandates service of notice to provide opportunity for revocation application, preventing permanent cancellation and business impediment. Coordinate Bench held that once returns accepted and no dues remain, Department should not obstruct business. Order cancelling registration quashed, petitioner directed to file reply to show cause notice within three weeks. Petition allowed.
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