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...
Cash receipts and repayments between an assessee and close family members, including related family entities, were not treated as loans or deposits under the relevant cash transaction provisions. The Tribunal noted that the family relationship was undisputed and applied the Gujarat High Court ratio in Dr. Rajaram L. Akhani to hold that such intra-family transactions do not fall within the mischief of the cash loan and deposit restrictions. As the statutory foundation for penalty failed, the penalties for cash acceptance and cash repayment were unsustainable and were deleted; both appeals were allowed.
Cash receipts and repayments between an assessee and close family members, including related family entities, were not treated as loans or deposits under the relevant cash transaction provisions. The Tribunal noted that the family relationship was undisputed and applied the Gujarat High Court ratio in Dr. Rajaram L. Akhani to hold that such intra-family transactions do not fall within the mischief of the cash loan and deposit restrictions. As the statutory foundation for penalty failed, the penalties for cash acceptance and cash repayment were unsustainable and were deleted; both appeals were allowed.
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