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 proceedings under ss. 271D and 271E were held unsustainable where the Revenue relied only on entries in seized papers belonging to third parties, without proving that the assessee actually accepted or repaid cash loans. The Tribunal held that such proceedings are penal in nature and independent of assessment proceedings, so the initial burden remained on the Revenue. That burden was not discharged because the documents were not shown to be the assessee's own records, no evidence proved utilisation or repayment, and the assessee's request for copies and cross-examination was denied. The penalties were deleted.
Penalty proceedings under ss. 271D and 271E were held unsustainable where the Revenue relied only on entries in seized papers belonging to third parties, without proving that the assessee actually accepted or repaid cash loans. The Tribunal held that such proceedings are penal in nature and independent of assessment proceedings, so the initial burden remained on the Revenue. That burden was not discharged because the documents were not shown to be the assessee's own records, no evidence proved utilisation or repayment, and the assessee's request for copies and cross-examination was denied. The penalties were deleted.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4809 
Join Channel 
