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...
HC quashed reassessment under Section 148 where the only basis was an entry in a broker's seized inquiry register. The Court held that seized material must have a live nexus with the assessee and must pertain to or relate to the assessee; here, the entry pre-dated the purchase by nearly twenty-three months, referred to lands available for sale, covered multiple survey numbers and a larger area, and named another person. On these facts, the register entry could not support a presumption of escapement of income, and the reopening was based on conjectures and surmises. The notice for the assessment year 2021-22 was quashed.
HC quashed reassessment under Section 148 where the only basis was an entry in a broker's seized inquiry register. The Court held that seized material must have a live nexus with the assessee and must pertain to or relate to the assessee; here, the entry pre-dated the purchase by nearly twenty-three months, referred to lands available for sale, covered multiple survey numbers and a larger area, and named another person. On these facts, the register entry could not support a presumption of escapement of income, and the reopening was based on conjectures and surmises. The notice for the assessment year 2021-22 was quashed.
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