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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The Tribunal held that the enhancement of the stamp duty valuation tolerance band from 5% to 10% was a curative, beneficial amendment applicable to A.Y. 2018-19, because it only relaxed the rigour of a deeming provision and did not create a new charge or fresh burden. It further held that the deeming fiction under section 56(2)(x)(b)(B) could not be invoked where the difference between the purchase consideration and the stamp duty value was 7.44%, being within the 10% band. The addition was deleted.
The Tribunal held that the enhancement of the stamp duty valuation tolerance band from 5% to 10% was a curative, beneficial amendment applicable to A.Y. 2018-19, because it only relaxed the rigour of a deeming provision and did not create a new charge or fresh burden. It further held that the deeming fiction under section 56(2)(x)(b)(B) could not be invoked where the difference between the purchase consideration and the stamp duty value was 7.44%, being within the 10% band. The addition was deleted.
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