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...
Assessment orders become effective only when signed, and dating an order within time does not satisfy the statutory limit if signature follows later. The HC held that for AY 2023-24, the limitation under section 153 expired on 31 March 2025, but the assessment order was digitally signed only on 25 December 2025. As the computation sheet and notice of demand were also signed after expiry of limitation, they were not validly made within time. Treating signature as an essential requirement of legal validity, the Court held the assessment order, computation sheet and notice of demand to be time-barred and quashed them.
Assessment orders become effective only when signed, and dating an order within time does not satisfy the statutory limit if signature follows later. The HC held that for AY 2023-24, the limitation under section 153 expired on 31 March 2025, but the assessment order was digitally signed only on 25 December 2025. As the computation sheet and notice of demand were also signed after expiry of limitation, they were not validly made within time. Treating signature as an essential requirement of legal validity, the Court held the assessment order, computation sheet and notice of demand to be time-barred and quashed them.
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