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...
Non-speaking assessment orders that do not address taxpayer submissions violate the principles of natural justice; the impugned orders confirming liability and referring to interest and penalty without reasoned findings were quashed and set aside. The respondents are directed to issue fresh show-cause notices, grant a personal hearing, and pass detailed, reasoned speaking orders expeditiously (preferably within one month of service). The court found mechanical adjudication caused prejudice and remanded the matter for fresh adjudication to cure the procedural defect.
Non-speaking assessment orders that do not address taxpayer submissions violate the principles of natural justice; the impugned orders confirming liability and referring to interest and penalty without reasoned findings were quashed and set aside. The respondents are directed to issue fresh show-cause notices, grant a personal hearing, and pass detailed, reasoned speaking orders expeditiously (preferably within one month of service). The court found mechanical adjudication caused prejudice and remanded the matter for fresh adjudication to cure the procedural defect.
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