Monthly Archives: May 2026

Supreme Court Dismisses Revenue’s SLP as Reassessment on Deactivated Predecessor PAN Is Void Issue Whether the revenue authority can validly initiate reassessment proceedings under Section 148A/148 against a successor company by targeting a predecessor entity’s PAN that was deactivated in 2009 pursuant to a court-approved amalgamation, despite the successor company repeatedly proving that all transactions… Read More »

Intra-Group Transfer of Shares to Wholly Owned Subsidiary Exempt From Capital Gains Under Section 47(iv) Issue Whether a French-based parent company’s transfer of 100% shares of an Indian subsidiary to another wholly owned Indian subsidiary constitutes a valid, tax-exempt capital asset reorganization under Section 47(iv) of the Income-tax Act, 1961, or whether it can be… Read More »

Depreciation Claimed On Goodwill Arising From Amalgamation Is Allowable Prior To Assessment Year 2021-22 Issue Whether the Assessing Officer was legally justified in disallowing the assessee’s claim for depreciation on goodwill under Section 32 of the Income-tax Act, 1961 for Assessment Years 2017-18 and 2018-19, when the statutory amendments excluding goodwill from depreciable assets apply… Read More »

Assessment Orders Quashed as Verification Remands and Conclusive Directions Both Missed Respective Limitation Periods Issue Whether the final assessment orders passed by the Assessing Officer to give effect to an ITAT remand order were barred by limitation, based on whether the specific directions required fresh verification of records under Section 153(3) or simple modification under… Read More »

Reassessment Proceedings Are Void Ab Initio As Notice Barred By Limitation Without Valid Tribunal Directions Issue Whether the Commissioner (Appeals) was legally justified in quashing reassessment proceedings and declaring the consequential assessment orders as void ab initio, on the grounds that the underlying directions under Section 150(2) had been expunged by the Tribunal, thereby rendering… Read More »