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...
Reassessment after search was held time-barred for A.Y. 2013-14 because the ten-year limit under section 149 extended only up to A.Y. 2014-15. For A.Ys. 2014-15 to 2017-18, reopening beyond six years failed because the alleged escaped income was not represented as an asset, so jurisdiction was lacking. For A.Ys. 2018-19 to 2020-21, the notices were invalid since the income alleged did not satisfy the statutory conditions for reopening beyond three years under section 149(1)(b). The Tribunal also reduced the gross profit rate on unaccounted sales to 10% for A.Y. 2021-22, held the post-search assessment for A.Y. 2022-23 invalid for want of section 148/148B procedure, and deleted the section 41(1) addition for A.Y. 2023-24 as no cessation of liability was shown.
Reassessment after search was held time-barred for A.Y. 2013-14 because the ten-year limit under section 149 extended only up to A.Y. 2014-15. For A.Ys. 2014-15 to 2017-18, reopening beyond six years failed because the alleged escaped income was not represented as an asset, so jurisdiction was lacking. For A.Ys. 2018-19 to 2020-21, the notices were invalid since the income alleged did not satisfy the statutory conditions for reopening beyond three years under section 149(1)(b). The Tribunal also reduced the gross profit rate on unaccounted sales to 10% for A.Y. 2021-22, held the post-search assessment for A.Y. 2022-23 invalid for want of section 148/148B procedure, and deleted the section 41(1) addition for A.Y. 2023-24 as no cessation of liability was shown.
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