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...
Delay in filing a GST appeal was treated as sufficiently explained where the order had been communicated to the Chartered Accountant, who failed to inform the taxpayer, and the mandatory pre-deposit was treated as substantial compliance with the appellate requirement. The note records that rejecting the appeal only on limitation, without considering the explanation, was viewed as a hyper-technical approach that could make the appellate remedy illusory, so the delay was condoned and the appeal was restored for hearing on merits. It also notes that the existing garnishee recovery, including freezing of bank accounts, was left in place until disposal of the appeal.
Delay in filing a GST appeal was treated as sufficiently explained where the order had been communicated to the Chartered Accountant, who failed to inform the taxpayer, and the mandatory pre-deposit was treated as substantial compliance with the appellate requirement. The note records that rejecting the appeal only on limitation, without considering the explanation, was viewed as a hyper-technical approach that could make the appellate remedy illusory, so the delay was condoned and the appeal was restored for hearing on merits. It also notes that the existing garnishee recovery, including freezing of bank accounts, was left in place until disposal of the appeal.
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