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...
A claim for exemption registration filed under the wrong section code required fresh scrutiny in light of Circular No. 7/2024 and the substance-over-form principle. The HC noted that the Tribunal had not examined the circular issue, and the appellant's assertion of system error was not established on the existing record. However, because the appellant had earlier held Section 12A registration, later obtained registration under Section 10(23), and surrendered it, the competent authority had to consider whether the mistaken code and fresh application brought the case within the circular. The impugned orders were set aside and the matter remitted for reconsideration without any view on merits.
A claim for exemption registration filed under the wrong section code required fresh scrutiny in light of Circular No. 7/2024 and the substance-over-form principle. The HC noted that the Tribunal had not examined the circular issue, and the appellant's assertion of system error was not established on the existing record. However, because the appellant had earlier held Section 12A registration, later obtained registration under Section 10(23), and surrendered it, the competent authority had to consider whether the mistaken code and fresh application brought the case within the circular. The impugned orders were set aside and the matter remitted for reconsideration without any view on merits.
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