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...
Whether disallowance under section 14A read with Rule 8D required prior recording of satisfaction: held that s.14A(2) mandates that the assessing officer must record satisfaction or dissatisfaction regarding the correctness of expenditure claimed before making an addition; absence of such recorded dissatisfaction renders the disallowance impermissible. Applying this legal precondition, the Tribunal and the appellate tax authority's factual findings rejecting the Revenue's adjustment were upheld and the Revenue's appeal dismissed. - HC
Whether disallowance under section 14A read with Rule 8D required prior recording of satisfaction: held that s.14A(2) mandates that the assessing officer must record satisfaction or dissatisfaction regarding the correctness of expenditure claimed before making an addition; absence of such recorded dissatisfaction renders the disallowance impermissible. Applying this legal precondition, the Tribunal and the appellate tax authority's factual findings rejecting the Revenue's adjustment were upheld and the Revenue's appeal dismissed. - HC
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