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...
Consistency in the assessee's own case governed the treatment of alleged notional interest on advances to a subsidiary: the addition was deleted because the issue had already been decided in the assessee's favour on identical facts, and the Revenue showed no distinguishing fact or change in law for the year. Pendency of earlier Revenue appeals before the High Court did not, by itself, justify departure from the settled view. The note records that the notional interest addition was therefore upheld as deleted for the relevant year.
Consistency in the assessee's own case governed the treatment of alleged notional interest on advances to a subsidiary: the addition was deleted because the issue had already been decided in the assessee's favour on identical facts, and the Revenue showed no distinguishing fact or change in law for the year. Pendency of earlier Revenue appeals before the High Court did not, by itself, justify departure from the settled view. The note records that the notional interest addition was therefore upheld as deleted for the relevant year.
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