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...
Reopening after four years was invalid because the recorded reasons did not a failure by the assessee to fully and truly disclose material facts in the original scrutiny assessment. The AO had already sought details of unsecured loans and the assessee had furnished confirmations before assessment under Section 143(3) was completed without addition on that issue. The reasons for reopening merely referred to survey information about bogus unsecured loans from shell companies, but did not identify the loans, entities, or connecting material. Such vague reasons could not be supplemented later through objections, a rejection order, or a subsequent notice. The Section 148 notice was quashed.
Reopening after four years was invalid because the recorded reasons did not a failure by the assessee to fully and truly disclose material facts in the original scrutiny assessment. The AO had already sought details of unsecured loans and the assessee had furnished confirmations before assessment under Section 143(3) was completed without addition on that issue. The reasons for reopening merely referred to survey information about bogus unsecured loans from shell companies, but did not identify the loans, entities, or connecting material. Such vague reasons could not be supplemented later through objections, a rejection order, or a subsequent notice. The Section 148 notice was quashed.
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