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...
Acceptance or repayment of loans through journal entries was treated as a violation of the statutory requirement to use recognised banking modes, attracting exposure to penalty under sections 271D and 271E. The Tribunal held that immunity under section 273B is available only where the assessee proves reasonable cause, and on the facts no compelling business necessity, unavoidable circumstance, or contemporaneous material was shown to justify bypassing normal banking channels. Mere assertions of bona fides, genuineness, or convenience were found insufficient. The penalties were therefore upheld and the appeals were dismissed.
Acceptance or repayment of loans through journal entries was treated as a violation of the statutory requirement to use recognised banking modes, attracting exposure to penalty under sections 271D and 271E. The Tribunal held that immunity under section 273B is available only where the assessee proves reasonable cause, and on the facts no compelling business necessity, unavoidable circumstance, or contemporaneous material was shown to justify bypassing normal banking channels. Mere assertions of bona fides, genuineness, or convenience were found insufficient. The penalties were therefore upheld and the appeals were dismissed.
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