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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Liability to pay cost recovery charges for customs officers deployed at a Container Freight Station was upheld because the regulatory framework, consistent administrative practice and the petitioner's own prior remittances showed that operators were liable unless expressly exempted. The Court applied contemporanea expositio and substantial compliance, finding that actual customs deployment and supervision satisfied the statutory purpose, and that later internal cadre regularisation did not extinguish the obligation. The challenge was also barred by res judicata and estoppel by conduct, since the liability issue had already been litigated and the petitioner had accepted the levy over time. The remaining quantification dispute was treated as factual and unsuitable for writ jurisdiction, and the cargo movement restriction was sustained as a lawful response to persistent non-payment.
Liability to pay cost recovery charges for customs officers deployed at a Container Freight Station was upheld because the regulatory framework, consistent administrative practice and the petitioner's own prior remittances showed that operators were liable unless expressly exempted. The Court applied contemporanea expositio and substantial compliance, finding that actual customs deployment and supervision satisfied the statutory purpose, and that later internal cadre regularisation did not extinguish the obligation. The challenge was also barred by res judicata and estoppel by conduct, since the liability issue had already been litigated and the petitioner had accepted the levy over time. The remaining quantification dispute was treated as factual and unsuitable for writ jurisdiction, and the cargo movement restriction was sustained as a lawful response to persistent non-payment.
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