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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On identical facts, the ITAT applied the principle of consistency and upheld assessment of only 1% commission on gross bank transactions, rejecting a broader addition. The Tribunal noted that in the preceding year the Assessing Officer had treated the assessee as a consignment sales agent for Khal Binola and taxed only commission income, and that tax deduction under section 194H supported the view that the bank deposits represented consignment sale proceeds on behalf of principals. Following Radhasoami Satsang and Excel Industries, the Tribunal sustained the addition only to that limited extent and deleted the balance.
On identical facts, the ITAT applied the principle of consistency and upheld assessment of only 1% commission on gross bank transactions, rejecting a broader addition. The Tribunal noted that in the preceding year the Assessing Officer had treated the assessee as a consignment sales agent for Khal Binola and taxed only commission income, and that tax deduction under section 194H supported the view that the bank deposits represented consignment sale proceeds on behalf of principals. Following Radhasoami Satsang and Excel Industries, the Tribunal sustained the addition only to that limited extent and deleted the balance.
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