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...
Penalty under section 271G for failure to furnish transfer pricing documentation could not survive once the underlying transfer pricing adjustment had been deleted and that deletion had been affirmed. The Tribunal held that, with the foundation of the penalty proceedings removed, there was no basis to sustain the penalty on the same transaction. The Revenue's challenge to deletion of the penalty failed, and the appellate order was upheld. The assessee's cross-objection was dismissed as infructuous because the remaining grounds had become academic.
Penalty under section 271G for failure to furnish transfer pricing documentation could not survive once the underlying transfer pricing adjustment had been deleted and that deletion had been affirmed. The Tribunal held that, with the foundation of the penalty proceedings removed, there was no basis to sustain the penalty on the same transaction. The Revenue's challenge to deletion of the penalty failed, and the appellate order was upheld. The assessee's cross-objection was dismissed as infructuous because the remaining grounds had become academic.
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