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...
A provision for ex gratia payment to employees on mercantile basis was allowable as business expenditure under section 37(1) because the Board had approved the liability and government approval for release did not make it contingent; the disallowance was deleted. In respect of exempt dividend income, disallowance under section 14A read with rule 8D failed because the Assessing Officer did not first examine the assessee's claim and record dissatisfaction on the basis of the accounts; that disallowance was deleted. Expenditure for increasing authorised share capital was held to be capital in nature and outside section 35D, so the disallowance was sustained. Penalty under section 271(1)(c) was deleted because the underlying issue was debatable and had been admitted by the High Court.
A provision for ex gratia payment to employees on mercantile basis was allowable as business expenditure under section 37(1) because the Board had approved the liability and government approval for release did not make it contingent; the disallowance was deleted. In respect of exempt dividend income, disallowance under section 14A read with rule 8D failed because the Assessing Officer did not first examine the assessee's claim and record dissatisfaction on the basis of the accounts; that disallowance was deleted. Expenditure for increasing authorised share capital was held to be capital in nature and outside section 35D, so the disallowance was sustained. Penalty under section 271(1)(c) was deleted because the underlying issue was debatable and had been admitted by the High Court.
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