Donor-directed corpus contributions retain capital character despite exemption claims under section 10(23C)(vi), preventing their treatment as taxable...
Enhanced tax-audit threshold applies where banking records establish compliant non-cash receipts and payments, eliminating penalty exposure for audit ...
Transfer pricing consistency protects identical non-interest-bearing debenture terms from a later notional-interest adjustment without valid statutory...
Rectification of debatable deduction claims cannot reverse scrutiny-approved co-operative society interest income deductions as apparent record errors...
Cash-method accounting bars presumptive interest taxation, while unsupported securities and share-trading additions require reliable material and veri...
Section 7 admission requires established financial debt and default, not precise interest quantification, while post-suspension defaults remain action...
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The Tribunal held that the statutory one-month timeline under section 148A(d) remains mandatory and is not extended by the broader surviving-period principle under section 148; the orders for AYs 2013-14 and 2014-15 were therefore time-barred and the consequential reassessment notices and orders were quashed. It further held that where action was founded solely on third-party search material, sections 153A/153C constituted the special route and general reassessment or assessment provisions could not be invoked without the required satisfaction note; the proceedings for AYs 2013-14, 2014-15 and 2020-21 were quashed on that ground. On merits, additions for accommodation entries, bank credits and duplicate loan credits were deleted because the sales and receipts were supported by records, bank statements are not books of account, and no objective inquiry or cash trail was shown.
The Tribunal held that the statutory one-month timeline under section 148A(d) remains mandatory and is not extended by the broader surviving-period principle under section 148; the orders for AYs 2013-14 and 2014-15 were therefore time-barred and the consequential reassessment notices and orders were quashed. It further held that where action was founded solely on third-party search material, sections 153A/153C constituted the special route and general reassessment or assessment provisions could not be invoked without the required satisfaction note; the proceedings for AYs 2013-14, 2014-15 and 2020-21 were quashed on that ground. On merits, additions for accommodation entries, bank credits and duplicate loan credits were deleted because the sales and receipts were supported by records, bank statements are not books of account, and no objective inquiry or cash trail was shown.
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