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...
Addition under section 56(2)(viib) on CCPS premium was deleted where the shares were issued under a reorganisation to the parent and existing shareholders, the valuation was supported by registered valuers or a merchant banker under Rule 11UA, and the transaction was not shown to be unaccounted money. The Tribunal also held that conversion of earlier CCPS into equity during the year did not attract section 56(2)(viib) for that assessment year. A year-end management fee reversal was remanded for fresh verification because the explanation lacked supporting evidence. Payments to MTH for transformation and related hotel services were held revenue in nature, and section 40A(2) was found inapplicable.
Addition under section 56(2)(viib) on CCPS premium was deleted where the shares were issued under a reorganisation to the parent and existing shareholders, the valuation was supported by registered valuers or a merchant banker under Rule 11UA, and the transaction was not shown to be unaccounted money. The Tribunal also held that conversion of earlier CCPS into equity during the year did not attract section 56(2)(viib) for that assessment year. A year-end management fee reversal was remanded for fresh verification because the explanation lacked supporting evidence. Payments to MTH for transformation and related hotel services were held revenue in nature, and section 40A(2) was found inapplicable.
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