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...
Section 7 admission requires established financial debt and default, not precise interest quantification, while post-suspension defaults remain action...
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A search assessment founded on a single consolidated satisfaction note covering multiple assessment years, without year-wise identification of material, was held to suffer from a fatal jurisdictional defect. The Tribunal held that the assessee could challenge the validity of the foundational assessment in appeal against the revision order, and that the original assessment was void in law because valid jurisdiction under the search assessment provisions had not been assumed for the year in question. As the foundational assessment was unsustainable, the revisionary order under section 263 could not survive and was set aside.
A search assessment founded on a single consolidated satisfaction note covering multiple assessment years, without year-wise identification of material, was held to suffer from a fatal jurisdictional defect. The Tribunal held that the assessee could challenge the validity of the foundational assessment in appeal against the revision order, and that the original assessment was void in law because valid jurisdiction under the search assessment provisions had not been assumed for the year in question. As the foundational assessment was unsustainable, the revisionary order under section 263 could not survive and was set aside.
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