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...
The text addresses denial of income tax refund applications where rejection rested solely on delay without applying the Supreme Court's exclusion of the limitation period from 15.03.2020 to 28.02.2022; the legal principle applied is that administrative refusals cannot ignore a binding judicial exclusion of limitation. Outcome: the impugned deficiency memos were quashed and the refund claims remitted for fresh, expeditious consideration in accordance with the exclusion, after affording the claimants a reasonable hearing and issuing a reasoned, speaking order.
The text addresses denial of income tax refund applications where rejection rested solely on delay without applying the Supreme Court's exclusion of the limitation period from 15.03.2020 to 28.02.2022; the legal principle applied is that administrative refusals cannot ignore a binding judicial exclusion of limitation. Outcome: the impugned deficiency memos were quashed and the refund claims remitted for fresh, expeditious consideration in accordance with the exclusion, after affording the claimants a reasonable hearing and issuing a reasoned, speaking order.
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