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...
Section 270A requires a prior determination of under reporting or misreporting of income before levy of penalty because the penalty is an additional tax dependent on basic tax liability; confirming penalty while a quantum appeal against a disallowance remained undecided was held impermissible as it adjudicated additional tax prematurely and infringed natural justice. The impugned penalty confirmation was quashed and the matter remitted for disposal of the quantum appeal first, after which penalty may be considered in accordance with law.
Section 270A requires a prior determination of under reporting or misreporting of income before levy of penalty because the penalty is an additional tax dependent on basic tax liability; confirming penalty while a quantum appeal against a disallowance remained undecided was held impermissible as it adjudicated additional tax prematurely and infringed natural justice. The impugned penalty confirmation was quashed and the matter remitted for disposal of the quantum appeal first, after which penalty may be considered in accordance with law.
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