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...
A High Court held that the six-month time limit for filing a rectification application under Notification No. 22/2024 is procedural and cannot defeat a substantive input tax credit benefit recognised by the retrospective insertion of Sections 16(5) and 16(6). On that basis, rejection of the application as time-barred was not sustained, and the matter was restored for fresh consideration on merits after notice. The respondent was permitted to verify actual entitlement, including whether input tax credit had in fact been availed and whether other statutory conditions were met.
A High Court held that the six-month time limit for filing a rectification application under Notification No. 22/2024 is procedural and cannot defeat a substantive input tax credit benefit recognised by the retrospective insertion of Sections 16(5) and 16(6). On that basis, rejection of the application as time-barred was not sustained, and the matter was restored for fresh consideration on merits after notice. The respondent was permitted to verify actual entitlement, including whether input tax credit had in fact been availed and whether other statutory conditions were met.
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