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...
Amalgamation assessment: the commentary concludes that income and disallowances of a predecessor for a period prior to amalgamation cannot be merged into a single reassessment order framed against the successor; such pre-amalgamation amounts must be assessed separately and, if at all, only under representative assessment provisions, and reliance on decisions about notices in the name of non-existent entities does not justify clubbing the predecessors income with the successors in one composite assessment. The revenues reassessment attempts to add predecessor period income in a single order are therefore unsustainable.
Amalgamation assessment: the commentary concludes that income and disallowances of a predecessor for a period prior to amalgamation cannot be merged into a single reassessment order framed against the successor; such pre-amalgamation amounts must be assessed separately and, if at all, only under representative assessment provisions, and reliance on decisions about notices in the name of non-existent entities does not justify clubbing the predecessors income with the successors in one composite assessment. The revenues reassessment attempts to add predecessor period income in a single order are therefore unsustainable.
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