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...
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Rectification was held maintainable where the earlier appellate direction wrongly assumed that land cost had not already been debited in the assessee's accounts and, under the joint development arrangement, treated construction cost as the assessee's cost. The Tribunal held that no provision allowed substitution of actual cost with fair market value or another notional value for computing profits for section 80-IB(10), so the deduction had to be recomputed on the profits disclosed in the Profit and Loss Account. It also held that the doctrine of merger did not apply because the earlier round had decided only eligibility in principle, not quantification, making rejection of rectification on merger grounds unjustified.
Rectification was held maintainable where the earlier appellate direction wrongly assumed that land cost had not already been debited in the assessee's accounts and, under the joint development arrangement, treated construction cost as the assessee's cost. The Tribunal held that no provision allowed substitution of actual cost with fair market value or another notional value for computing profits for section 80-IB(10), so the deduction had to be recomputed on the profits disclosed in the Profit and Loss Account. It also held that the doctrine of merger did not apply because the earlier round had decided only eligibility in principle, not quantification, making rejection of rectification on merger grounds unjustified.
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