Political contribution deductions require genuine transactions; banking records and party registration alone cannot defeat evidence of accommodation e...
Post-death GST liability permits fresh proceedings against legal representatives, while discontinued-business recovery remains limited to the inherite...
Non-confirmation of FEMA seizure prevents adjudicators from overriding pending appellate findings on recorded reasons and suspected foreign asset hold...
The dominant issue was whether revision under s.263 could be sustained on the premise that carry forward of unabsorbed depreciation and business losses was wrongly allowed due to non-fulfilment of the three-year existence condition in s.72A(2). The court held that s.72A(4), applicable to a demerger, contains no such condition, and the record showed the authority was aware of the assessee's reliance on this distinction. As the revisional authority neither identified a concrete error in the assessment nor articulated any specific doubt despite available scheme orders, the s.263 direction was held to be a roving enquiry and invalid; questions were answered in favour of the assessee. - HC
The dominant issue was whether revision under s.263 could be sustained on the premise that carry forward of unabsorbed depreciation and business losses was wrongly allowed due to non-fulfilment of the three-year existence condition in s.72A(2). The court held that s.72A(4), applicable to a demerger, contains no such condition, and the record showed the authority was aware of the assessee's reliance on this distinction. As the revisional authority neither identified a concrete error in the assessment nor articulated any specific doubt despite available scheme orders, the s.263 direction was held to be a roving enquiry and invalid; questions were answered in favour of the assessee. - HC
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
