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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ITAT applied the real income theory to hold that alleged bonus or commission receivable could not be taxed on a due basis where there was no proof of receipt, no employer provisioning, and no document showing a legal right to receive the amount; the deletion of that addition was upheld. On the unexplained money issue, the Tribunal accepted third-party confirmations, agreements, revenue records and section 133(6) responses admitting cash handed over for proposed land transactions, and directed deletion of Rs. 85,00,000. For the remaining cash addition, it held that bare assertions of cash savings and business receipts were insufficient without corroboration, so the relief already granted by the first appellate authority was sustained and no further interference was warranted.
ITAT applied the real income theory to hold that alleged bonus or commission receivable could not be taxed on a due basis where there was no proof of receipt, no employer provisioning, and no document showing a legal right to receive the amount; the deletion of that addition was upheld. On the unexplained money issue, the Tribunal accepted third-party confirmations, agreements, revenue records and section 133(6) responses admitting cash handed over for proposed land transactions, and directed deletion of Rs. 85,00,000. For the remaining cash addition, it held that bare assertions of cash savings and business receipts were insufficient without corroboration, so the relief already granted by the first appellate authority was sustained and no further interference was warranted.
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