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...
Assessing Officer initiated proceedings under section 147 solely on the basis of incriminating material seized during a search of a third party, but where information pertains to a person other than the searched party the proper statutory route is assessment under section 153C; therefore the AO lacked jurisdiction to proceed under section 147 and the appellate authority correctly quashed the 147 proceedings. Separately, additions for alleged 'on money' receipts were deleted because the AO extrapolated figures from seized documents without any corroborative evidence or independent inquiry, rendering the additions speculative and unsupported.
Assessing Officer initiated proceedings under section 147 solely on the basis of incriminating material seized during a search of a third party, but where information pertains to a person other than the searched party the proper statutory route is assessment under section 153C; therefore the AO lacked jurisdiction to proceed under section 147 and the appellate authority correctly quashed the 147 proceedings. Separately, additions for alleged 'on money' receipts were deleted because the AO extrapolated figures from seized documents without any corroborative evidence or independent inquiry, rendering the additions speculative and unsupported.
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