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 270AA gives finality where an assessee accepts the assessment without appeal and secures immunity from penalty and prosecution; a later section 154 rectification cannot be used to substantially rewrite the assessment or change its tax consequence, so the rectification order was without jurisdiction. An ad hoc disallowance of expenditure already recorded in the books and reflected in the accounts is not unexplained expenditure under section 69C; it is only an estimated disallowance for want of verification, so section 115BBE could not be applied in rectification proceedings. The Tribunal quashed both the rectification order and the appellate order affirming it.
Section 270AA gives finality where an assessee accepts the assessment without appeal and secures immunity from penalty and prosecution; a later section 154 rectification cannot be used to substantially rewrite the assessment or change its tax consequence, so the rectification order was without jurisdiction. An ad hoc disallowance of expenditure already recorded in the books and reflected in the accounts is not unexplained expenditure under section 69C; it is only an estimated disallowance for want of verification, so section 115BBE could not be applied in rectification proceedings. The Tribunal quashed both the rectification order and the appellate order affirming it.
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