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 of assessment was held invalid where the PCIT's approval consisted only of the terse statement "yes, I am satisfied" without recorded reasons; such mechanical approval fails the requirement that the approving officer must record satisfaction and reasons, rendering the issuance of notice and consequential assessment legally unsustainable. The tribunal relied on precedent holding similar formulaic endorsements inadequate, and accordingly quashed the notice for reopening and the assessment framed following that approval for want of valid administrative satisfaction.
Reopening of assessment was held invalid where the PCIT's approval consisted only of the terse statement "yes, I am satisfied" without recorded reasons; such mechanical approval fails the requirement that the approving officer must record satisfaction and reasons, rendering the issuance of notice and consequential assessment legally unsustainable. The tribunal relied on precedent holding similar formulaic endorsements inadequate, and accordingly quashed the notice for reopening and the assessment framed following that approval for want of valid administrative satisfaction.
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