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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Non-filing of returns by some suppliers, without further enquiry or contrary material, was held insufficient to reject recorded purchases where payments were through banking channels and sales were accepted; the ad hoc gross profit addition on disputed purchases was deleted. For unaccounted sales, only the profit element was treated as taxable, and the income was estimated on a net profit basis at 2% rather than by taxing the entire sales. Alleged entry-fee receipts based on extrapolation from a limited period were curtailed, with only 25% of the estimated addition sustained. Separate addition for unexplained expenditure was deleted on telescoping, as the sustained undisclosed income was treated as available to meet that expenditure.
Non-filing of returns by some suppliers, without further enquiry or contrary material, was held insufficient to reject recorded purchases where payments were through banking channels and sales were accepted; the ad hoc gross profit addition on disputed purchases was deleted. For unaccounted sales, only the profit element was treated as taxable, and the income was estimated on a net profit basis at 2% rather than by taxing the entire sales. Alleged entry-fee receipts based on extrapolation from a limited period were curtailed, with only 25% of the estimated addition sustained. Separate addition for unexplained expenditure was deleted on telescoping, as the sustained undisclosed income was treated as available to meet that expenditure.
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