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...
In bank tax assessments, the Tribunal held that the opening FCTR (Foreign Currency Translation Reserve) balance could not be taxed under ICDS-VI where the Act taxes only current-year income, and a CBDT circular cannot override sections 4 and 5. It also held that section 115JB does not apply to corresponding new banks, and that section 14A cannot be invoked for securities held as stock-in-trade. Reassessment based only on existing records was invalid for want of fresh tangible material, and an assessment on an amalgamated, non-existing entity was a jurisdictional nullity. The Tribunal further upheld relief on bad debts, refund interest, NPA interest, regulatory payments, perpetual bond interest, HTM premium amortisation, wage revision provision, and depreciation on investments.
In bank tax assessments, the Tribunal held that the opening FCTR (Foreign Currency Translation Reserve) balance could not be taxed under ICDS-VI where the Act taxes only current-year income, and a CBDT circular cannot override sections 4 and 5. It also held that section 115JB does not apply to corresponding new banks, and that section 14A cannot be invoked for securities held as stock-in-trade. Reassessment based only on existing records was invalid for want of fresh tangible material, and an assessment on an amalgamated, non-existing entity was a jurisdictional nullity. The Tribunal further upheld relief on bad debts, refund interest, NPA interest, regulatory payments, perpetual bond interest, HTM premium amortisation, wage revision provision, and depreciation on investments.
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