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...
Penalty for non-disclosure of foreign assets was not sustained where the assessee disclosed the assets and foreign income in the return filed after search, and that return operated as the substituted return in place of the original return. Because the Revenue accepted the disclosure, made no addition in the assessment framed on the later return, and produced no material showing deliberate tax evasion, the earlier omission from the original return was treated as a bona fide technical lapse. On those facts, deletion of penalty under the Black Money Act was upheld.
Penalty for non-disclosure of foreign assets was not sustained where the assessee disclosed the assets and foreign income in the return filed after search, and that return operated as the substituted return in place of the original return. Because the Revenue accepted the disclosure, made no addition in the assessment framed on the later return, and produced no material showing deliberate tax evasion, the earlier omission from the original return was treated as a bona fide technical lapse. On those facts, deletion of penalty under the Black Money Act was upheld.
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