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...
Revisional jurisdiction under section 264 is benevolent and cannot be used to place an assessee in a worse position; the ITAT held that, while giving effect to the revision, the AO could not reopen matters already accepted and enhance the addition. On facts, the assessee's only income was salary received in cash, that source was undisputed, and the explanation that the balance demonetisation cash deposits came from past salary savings was treated as reasonable despite the absence of further documentation. The addition for unexplained cash deposits was deleted, and the connected duplicate appeal was dismissed.
Revisional jurisdiction under section 264 is benevolent and cannot be used to place an assessee in a worse position; the ITAT held that, while giving effect to the revision, the AO could not reopen matters already accepted and enhance the addition. On facts, the assessee's only income was salary received in cash, that source was undisputed, and the explanation that the balance demonetisation cash deposits came from past salary savings was treated as reasonable despite the absence of further documentation. The addition for unexplained cash deposits was deleted, and the connected duplicate appeal was dismissed.
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