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...
Taxability of distribution fee earned for granting BBC News Channel distribution rights was not decided on merits, as the assessee had raised a fresh claim before the appellate stage after originally offering the amount to tax. Taking note of the CBDT circular that only legitimate tax should be assessed and collected, the ITAT restored the matter to the Jurisdictional Assessing Officer for de novo consideration on merits, with due opportunity of hearing to the assessee. The appeal was allowed for statistical purposes, and the question of tax liability remained open.
Taxability of distribution fee earned for granting BBC News Channel distribution rights was not decided on merits, as the assessee had raised a fresh claim before the appellate stage after originally offering the amount to tax. Taking note of the CBDT circular that only legitimate tax should be assessed and collected, the ITAT restored the matter to the Jurisdictional Assessing Officer for de novo consideration on merits, with due opportunity of hearing to the assessee. The appeal was allowed for statistical purposes, and the question of tax liability remained open.
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