The Bombay High Court held that assessment proceedings conducted in the name of a company that ceased to exist after amalgamation are void. All related notices and orders were set aside. The ruling confirms that jurisdiction cannot be assumed over a non-existent entity.
The ITAT upheld ₹90 lakh addition as the assessee failed to establish genuineness and creditworthiness of the transaction. The ruling emphasizes the burden of proof on taxpayers in cash credit cases.
The ITAT held that the PCIT cannot invoke revisionary powers when the same issue is already pending before the appellate authority. The case involved share transaction additions treated as penny stock.
The Supreme Court declined to recall its earlier order, effectively upholding the High Court ruling that TDS was not applicable on payments for imported Business Information Reports. The decision affirms reliance on consistent AAR rulings.
The Bombay High Court upheld ITAT’s ruling that payments for Business Information Reports did not attract TDS under Section 195. The decision relied on consistent AAR rulings on identical facts.
The Court held that once a resolution plan is approved, prior tax liabilities stand extinguished. Reassessment under Section 148 was therefore unsustainable.
The High Court held that once a resolution plan under IBC extinguishes prior tax liabilities, reassessment cannot be initiated. The notice under Section 148 was set aside. The ruling confirms that extinguished claims cannot be revived through reassessment.