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...
Validity of reassessment notices under sections 148 and 148A was not examined on merits because the HC followed the Supreme Court's approach in an identical matter after insertion of section 147A. The writ appeals were allowed, the Single Judge's orders were set aside, and the matters were remitted for fresh consideration. The assessees were given liberty to amend the writ petitions to challenge section 147A and any connected or consequential provision, with all rival contentions left open for decision on remand.
Validity of reassessment notices under sections 148 and 148A was not examined on merits because the HC followed the Supreme Court's approach in an identical matter after insertion of section 147A. The writ appeals were allowed, the Single Judge's orders were set aside, and the matters were remitted for fresh consideration. The assessees were given liberty to amend the writ petitions to challenge section 147A and any connected or consequential provision, with all rival contentions left open for decision on remand.
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