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...
The Tribunal held that the extended reassessment period beyond three years was unavailable because the alleged escaped income related only to a claimed donation deduction and did not meet the statutory monetary threshold for extension. It further found that, even after excluding the time allowed to respond to the section 148A(b) notice, the Assessing Officer had time only until 07/04/2023 to issue the reassessment notice, but it was issued on 10/04/2023. The sixth proviso was therefore inapplicable, and the reassessment notice was time-barred and invalid; the merits of the disallowance were left open.
The Tribunal held that the extended reassessment period beyond three years was unavailable because the alleged escaped income related only to a claimed donation deduction and did not meet the statutory monetary threshold for extension. It further found that, even after excluding the time allowed to respond to the section 148A(b) notice, the Assessing Officer had time only until 07/04/2023 to issue the reassessment notice, but it was issued on 10/04/2023. The sixth proviso was therefore inapplicable, and the reassessment notice was time-barred and invalid; the merits of the disallowance were left open.
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