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...
After the 01.04.1989 amendment, delayed payment of self-assessment tax under section 140A(3) no longer attracted penalty; the provision treated the assessee as in default only for recovery of unpaid tax and interest. In the absence of any corresponding expansion of section 221(1), penalty could not be imposed for such default under section 140A(3) read with section 221(1). The Tribunal therefore held the penalty unsustainable in law and directed its deletion. The issue of sufficient cause for the delay became academic once statutory authority for the penalty itself was lacking.
After the 01.04.1989 amendment, delayed payment of self-assessment tax under section 140A(3) no longer attracted penalty; the provision treated the assessee as in default only for recovery of unpaid tax and interest. In the absence of any corresponding expansion of section 221(1), penalty could not be imposed for such default under section 140A(3) read with section 221(1). The Tribunal therefore held the penalty unsustainable in law and directed its deletion. The issue of sufficient cause for the delay became academic once statutory authority for the penalty itself was lacking.
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