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...
Reopening under section 147 after a search was upheld, as the tribunal found no infirmity in the assumption of jurisdiction and rejected the challenge to validity of reassessment. On the merits, commission income from an accommodation entry operation was to be estimated at 0.15%, not the higher rate proposed by the Assessing Officer, but the quantification basis was vitiated because the tally data and forensic analysis report had not been confronted to the assessee. That breach of natural justice required fresh computation. The matter was remanded to the Assessing Officer to supply the material, consider the assessee's submissions, recompute turnover, and then apply the 0.15% rate; the Revenue's challenge to that rate was dismissed.
Reopening under section 147 after a search was upheld, as the tribunal found no infirmity in the assumption of jurisdiction and rejected the challenge to validity of reassessment. On the merits, commission income from an accommodation entry operation was to be estimated at 0.15%, not the higher rate proposed by the Assessing Officer, but the quantification basis was vitiated because the tally data and forensic analysis report had not been confronted to the assessee. That breach of natural justice required fresh computation. The matter was remanded to the Assessing Officer to supply the material, consider the assessee's submissions, recompute turnover, and then apply the 0.15% rate; the Revenue's challenge to that rate was dismissed.
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