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 short-deduction demand on purchase of immovable property was held unsustainable where the seller's PAN was later regularised through Aadhaar linkage within the CBDT circular period, so the higher TDS rate for an inoperative PAN did not apply and the related demand under section 200A had to be deleted. Independently, the proviso to section 201(1) protected the deductor because the seller had filed the return, declared the capital gains, and paid tax on the transaction, so the deductor could not be treated as an assessee-in-default. The Tribunal also noted that similar relief had already been granted in the co-owner's case.
A short-deduction demand on purchase of immovable property was held unsustainable where the seller's PAN was later regularised through Aadhaar linkage within the CBDT circular period, so the higher TDS rate for an inoperative PAN did not apply and the related demand under section 200A had to be deleted. Independently, the proviso to section 201(1) protected the deductor because the seller had filed the return, declared the capital gains, and paid tax on the transaction, so the deductor could not be treated as an assessee-in-default. The Tribunal also noted that similar relief had already been granted in the co-owner's case.
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