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...
Bogus purchases from accommodation entry providers were not disallowed in full where the assessee's sales were undisputed and it had maintained quantitative details, stock records, purchase and sales registers, and banking trail. The Tribunal noted that the suppliers were found non-genuine in investigation, but the record did not support an inference that no purchases had been made at all. In such circumstances, only the profit element embedded in the alleged bogus purchases could be taxed, on the footing that goods may have been sourced from the grey market and bills obtained from named parties. The disallowance was therefore restricted to 10% and the balance addition was deleted.
Bogus purchases from accommodation entry providers were not disallowed in full where the assessee's sales were undisputed and it had maintained quantitative details, stock records, purchase and sales registers, and banking trail. The Tribunal noted that the suppliers were found non-genuine in investigation, but the record did not support an inference that no purchases had been made at all. In such circumstances, only the profit element embedded in the alleged bogus purchases could be taxed, on the footing that goods may have been sourced from the grey market and bills obtained from named parties. The disallowance was therefore restricted to 10% and the balance addition was deleted.
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