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...
Revenue-sharing under a participative railway infrastructure arrangement was treated as a joint venture-like model, not as business support service, because freight collections were shared as a return on capital investment with profit and not as consideration for any identified service. The text notes that there was no service provider-recipient relationship or direct quid pro quo, so the demand on that footing was not sustainable. It also records that a bona fide belief, supported by prior Tribunal rulings on similar arrangements, defeated suppression, making the extended limitation period unavailable.
Revenue-sharing under a participative railway infrastructure arrangement was treated as a joint venture-like model, not as business support service, because freight collections were shared as a return on capital investment with profit and not as consideration for any identified service. The text notes that there was no service provider-recipient relationship or direct quid pro quo, so the demand on that footing was not sustainable. It also records that a bona fide belief, supported by prior Tribunal rulings on similar arrangements, defeated suppression, making the extended limitation period unavailable.
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