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...
Co-terminus appellate powers permit a first appellate authority to remit a matter for fresh factual verification where the assessment was made ex parte and substantial documentary evidence, including ledger accounts, invoices, gate passes, weighment slips, financial statements, audit report and bank statements, requires examination. The Tribunal upheld the remand for denovo adjudication because proper verification of the sales transactions was necessary and no prejudice to the Revenue was shown. It also held that notice under section 143(2) is a mandatory precondition for a valid reassessment after a return is filed in response to section 148, and that section 292BB cannot cure a complete absence of such notice. The reassessment was therefore void and the addition was deleted.
Co-terminus appellate powers permit a first appellate authority to remit a matter for fresh factual verification where the assessment was made ex parte and substantial documentary evidence, including ledger accounts, invoices, gate passes, weighment slips, financial statements, audit report and bank statements, requires examination. The Tribunal upheld the remand for denovo adjudication because proper verification of the sales transactions was necessary and no prejudice to the Revenue was shown. It also held that notice under section 143(2) is a mandatory precondition for a valid reassessment after a return is filed in response to section 148, and that section 292BB cannot cure a complete absence of such notice. The reassessment was therefore void and the addition was deleted.
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