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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The Tribunal upheld provisional attachment of flats, parking spaces and agricultural land as equivalent-value property under PMLA, finding that the assets were purchased during the period of criminal activity after receipt of funds treated as proceeds of crime. The appellants' claim that the properties were acquired before the scheduled offence was rejected because the record showed otherwise and no legitimate source of acquisition was proved. It also held that the date of registration of the criminal case was not decisive, and declined to apply Seema Garg in light of later Supreme Court and High Court interpretation that proceeds of crime can cover property of equivalent value. The confirmation of attachment was sustained and both appeals were dismissed.
The Tribunal upheld provisional attachment of flats, parking spaces and agricultural land as equivalent-value property under PMLA, finding that the assets were purchased during the period of criminal activity after receipt of funds treated as proceeds of crime. The appellants' claim that the properties were acquired before the scheduled offence was rejected because the record showed otherwise and no legitimate source of acquisition was proved. It also held that the date of registration of the criminal case was not decisive, and declined to apply Seema Garg in light of later Supreme Court and High Court interpretation that proceeds of crime can cover property of equivalent value. The confirmation of attachment was sustained and both appeals were dismissed.
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