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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ITAT deleted penalty under section 271D where the notice was defective and the alleged contravention did not match the penalty finally imposed: the notice referred to section 271DA read with section 269ST, while the penalty was levied for violation of section 269SS. On merits, the cash receipt formed part of a genuine sale transaction, the Revenue did not dispute that the property deal had materialised, part of the consideration had been paid through banking channels, and the tax consequences were disclosed by the assessee. The Tribunal also noted practical difficulty arising from the purchaser's non-resident status. In these circumstances, the penalty was held unsustainable.
ITAT deleted penalty under section 271D where the notice was defective and the alleged contravention did not match the penalty finally imposed: the notice referred to section 271DA read with section 269ST, while the penalty was levied for violation of section 269SS. On merits, the cash receipt formed part of a genuine sale transaction, the Revenue did not dispute that the property deal had materialised, part of the consideration had been paid through banking channels, and the tax consequences were disclosed by the assessee. The Tribunal also noted practical difficulty arising from the purchaser's non-resident status. In these circumstances, the penalty was held unsustainable.
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