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...
Reopening an income-tax assessment for the identical bank-deposit transaction already investigated and finally adjudicated is impermissible where the subsequent authority relies on the same material; the doctrine Nemo debet bis vexari pro una et eadem causa bars subjecting the assessee to duplicate adjudication. The court reiterates that a notice under section 148 requires "reasons to believe" grounded in tangible material with a nexus to escaped income and cannot be based on mere suspicion or a change of opinion. The reassessment attempt was self conflicting and set aside; the writ petition was allowed, preventing a second assessment on the same subject matter.
Reopening an income-tax assessment for the identical bank-deposit transaction already investigated and finally adjudicated is impermissible where the subsequent authority relies on the same material; the doctrine Nemo debet bis vexari pro una et eadem causa bars subjecting the assessee to duplicate adjudication. The court reiterates that a notice under section 148 requires "reasons to believe" grounded in tangible material with a nexus to escaped income and cannot be based on mere suspicion or a change of opinion. The reassessment attempt was self conflicting and set aside; the writ petition was allowed, preventing a second assessment on the same subject matter.
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