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 assessing officers must verify claimed TDS credits and whether courts may direct automated software changes to prevent demands: the Court held that the Assessing Officer must examine factual records before waiving liability for undeposited TDS, since technology aids processing but cannot replace adjudication; therefore verification and, where necessary, show-cause procedures remain essential - outcome: AO's verification duty affirmed. Whether High Court could order departmental software modifications and automatic non-raising of demands: the Court held such directions intrude on adjudicatory functions and risk ignoring genuine demands - outcome: directions to modify the software were set aside. - SC
Whether assessing officers must verify claimed TDS credits and whether courts may direct automated software changes to prevent demands: the Court held that the Assessing Officer must examine factual records before waiving liability for undeposited TDS, since technology aids processing but cannot replace adjudication; therefore verification and, where necessary, show-cause procedures remain essential - outcome: AO's verification duty affirmed. Whether High Court could order departmental software modifications and automatic non-raising of demands: the Court held such directions intrude on adjudicatory functions and risk ignoring genuine demands - outcome: directions to modify the software were set aside. - SC
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