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...
Where reassessment was based entirely on seized material found during search on a third party, section 153C was the proper mechanism because it specifically governs assessment of a person other than the searched person on the basis of such material; recourse to section 147 was held impermissible and the section 148 notices were quashed. The reassessment also failed because the Assessing Officer had not made any independent enquiry or formed his own satisfaction, and had acted only on information from the Investigation Wing. On both grounds, the reassessment proceedings for the relevant assessment years were held to be without jurisdiction and were quashed.
Where reassessment was based entirely on seized material found during search on a third party, section 153C was the proper mechanism because it specifically governs assessment of a person other than the searched person on the basis of such material; recourse to section 147 was held impermissible and the section 148 notices were quashed. The reassessment also failed because the Assessing Officer had not made any independent enquiry or formed his own satisfaction, and had acted only on information from the Investigation Wing. On both grounds, the reassessment proceedings for the relevant assessment years were held to be without jurisdiction and were quashed.
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