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 an assessment requires contemporaneous reasons to believe supported by tangible material and a live link to escapement of income; a mere recalculation of full value of consideration using lowest prevailing market value or a change of opinion is insufficient. The taxpayer had already provided stock valuation details and basis in response to queries under section 142(1), and the subsequent communications did not disclose fresh tangible material or a live link justifying reassessment under section 147. The impugned reopening notices were therefore held to lack jurisdiction and were quashed in favour of the assessee.
Reopening an assessment requires contemporaneous reasons to believe supported by tangible material and a live link to escapement of income; a mere recalculation of full value of consideration using lowest prevailing market value or a change of opinion is insufficient. The taxpayer had already provided stock valuation details and basis in response to queries under section 142(1), and the subsequent communications did not disclose fresh tangible material or a live link justifying reassessment under section 147. The impugned reopening notices were therefore held to lack jurisdiction and were quashed in favour of the assessee.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4809 
Join Channel 
