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...
Reopening initiated in the individual's name but assessment subsequently framed on an association of persons was held impermissible; the tribunal found that changing the assessed status from individual to AOP during reassessment vitiates jurisdiction and procedure, rendering the reassessment order invalid. Consequently the reassessment order was quashed and the taxpayer's appeal allowed, on the basis that assessment must remain within the status named in the reopening notice and cannot be altered to substitute or create a different taxable status.
Reopening initiated in the individual's name but assessment subsequently framed on an association of persons was held impermissible; the tribunal found that changing the assessed status from individual to AOP during reassessment vitiates jurisdiction and procedure, rendering the reassessment order invalid. Consequently the reassessment order was quashed and the taxpayer's appeal allowed, on the basis that assessment must remain within the status named in the reopening notice and cannot be altered to substitute or create a different taxable status.
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