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...
Common area maintenance charges paid under separate service arrangements were treated as contractual payments, not rent, because they did not represent consideration for use of land, building or premises. The Tribunal followed its earlier co-ordinate Bench view and held that TDS was correctly deducted under section 194C on maintenance services, not under section 194I. The Revenue's short-deduction demand under sections 201(1) and 201(1A) therefore did not survive, and the relief granted by the CIT(A) was upheld for all three assessment years.
Common area maintenance charges paid under separate service arrangements were treated as contractual payments, not rent, because they did not represent consideration for use of land, building or premises. The Tribunal followed its earlier co-ordinate Bench view and held that TDS was correctly deducted under section 194C on maintenance services, not under section 194I. The Revenue's short-deduction demand under sections 201(1) and 201(1A) therefore did not survive, and the relief granted by the CIT(A) was upheld for all three assessment years.
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