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 271(1)(c) could not survive once the related interest disallowance under section 36(1)(iii) had already been deleted in the quantum appeal, because the basis for the penalty no longer existed. On the subsidy issue, the Tribunal treated the capital-versus-revenue characterisation of the grant as a debatable question and held that such a disputed classification did not establish concealment or furnishing of inaccurate particulars. The penalty was therefore deleted in full.
Penalty under section 271(1)(c) could not survive once the related interest disallowance under section 36(1)(iii) had already been deleted in the quantum appeal, because the basis for the penalty no longer existed. On the subsidy issue, the Tribunal treated the capital-versus-revenue characterisation of the grant as a debatable question and held that such a disputed classification did not establish concealment or furnishing of inaccurate particulars. The penalty was therefore deleted in full.
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