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...
Assessment in the earlier company name was held valid where the assessee's own communications continued to use the old name, creating a bona fide impression on the tax authority; consequently the assessment was not void. Separately, additions treating subscribed share capital and premium as not genuine were sustained because the offered valuation was unacceptable, investor creditworthiness and non-responses were unsatisfactory, and the transactional sequence indicated profiteering through transfer; therefore the premium component was disallowed and additions upheld under the tax provisions addressing non-genuine share allotments and deemed income.
Assessment in the earlier company name was held valid where the assessee's own communications continued to use the old name, creating a bona fide impression on the tax authority; consequently the assessment was not void. Separately, additions treating subscribed share capital and premium as not genuine were sustained because the offered valuation was unacceptable, investor creditworthiness and non-responses were unsatisfactory, and the transactional sequence indicated profiteering through transfer; therefore the premium component was disallowed and additions upheld under the tax provisions addressing non-genuine share allotments and deemed income.
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