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 proceedings under the GST enactments must be confined to the relevant tax period, and a single composite show cause notice or composite assessment order for multiple assessment years is impermissible. Following prior High Court authority, the court held that the impugned DRC-01 notice and assessment order, both framed on a combined basis, were unsustainable; separate issuance of DRC-07 did not cure the defect. The composite assessment order was set aside, and the respondents were given liberty to initiate fresh year-wise proceedings. The period from the impugned order until receipt of the court's order was directed to be excluded for limitation purposes.
Assessment proceedings under the GST enactments must be confined to the relevant tax period, and a single composite show cause notice or composite assessment order for multiple assessment years is impermissible. Following prior High Court authority, the court held that the impugned DRC-01 notice and assessment order, both framed on a combined basis, were unsustainable; separate issuance of DRC-07 did not cure the defect. The composite assessment order was set aside, and the respondents were given liberty to initiate fresh year-wise proceedings. The period from the impugned order until receipt of the court's order was directed to be excluded for limitation purposes.
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