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...
Faceless assessment scheme does not absorb the statutory preliminary inquiry procedure for reopening; the scheme's plain language excludes that inquiry process, so a notice to reopen may validly be issued by the jurisdictional assessing officer where the requisite inquiry and order were made by that officer. Reading the faceless scheme to incorporate the preliminary inquiry would alter the scheme and render issuance by a faceless officer meaningless. Conflicting views from other High Courts were noted, but the conclusion here is that automated allocation may trigger notice issuance while reassessment proceedings may proceed facelessly; notices issued by jurisdictional officers after April 2022 are upheld as valid.
Faceless assessment scheme does not absorb the statutory preliminary inquiry procedure for reopening; the scheme's plain language excludes that inquiry process, so a notice to reopen may validly be issued by the jurisdictional assessing officer where the requisite inquiry and order were made by that officer. Reading the faceless scheme to incorporate the preliminary inquiry would alter the scheme and render issuance by a faceless officer meaningless. Conflicting views from other High Courts were noted, but the conclusion here is that automated allocation may trigger notice issuance while reassessment proceedings may proceed facelessly; notices issued by jurisdictional officers after April 2022 are upheld as valid.
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