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...
Third-party seized documents cannot, by themselves, sustain an addition where the assessee denies receipt of cash and no independent corroboration such as a cash trail or confirmation is produced; the ITAT held that the presumption under section 132(4A) read with section 292C does not operate against an assessee for material found at a third party's premises, so the addition failed. A receipt linked to a joint development agreement could not be taxed as income from other sources under section 56 without first examining whether it arose from a transfer of a capital asset and the correct year of taxability under the capital gains provisions; as the required transfer analysis was not undertaken, the addition was deleted.
Third-party seized documents cannot, by themselves, sustain an addition where the assessee denies receipt of cash and no independent corroboration such as a cash trail or confirmation is produced; the ITAT held that the presumption under section 132(4A) read with section 292C does not operate against an assessee for material found at a third party's premises, so the addition failed. A receipt linked to a joint development agreement could not be taxed as income from other sources under section 56 without first examining whether it arose from a transfer of a capital asset and the correct year of taxability under the capital gains provisions; as the required transfer analysis was not undertaken, the addition was deleted.
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