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...
Extended limitation was held applicable because the investigation materials showed wilful misstatement and suppression of facts, including diversion of duty-free imports, use of an incorrect export code, and alleged manipulation of export documentation. The plea that the discrepancy was merely clerical was rejected, and the show cause notice was treated as timely. The requirement of pre-deposit was also upheld as reasonable because the appellants could not rely on parity with an earlier order involving different facts and limited bills of entry. On that basis, the direction to deposit amounts and the dismissal of the appeals for non-compliance were sustained.
Extended limitation was held applicable because the investigation materials showed wilful misstatement and suppression of facts, including diversion of duty-free imports, use of an incorrect export code, and alleged manipulation of export documentation. The plea that the discrepancy was merely clerical was rejected, and the show cause notice was treated as timely. The requirement of pre-deposit was also upheld as reasonable because the appellants could not rely on parity with an earlier order involving different facts and limited bills of entry. On that basis, the direction to deposit amounts and the dismissal of the appeals for non-compliance were sustained.
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