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...
Protective addition failed where the cash allegedly routed for gold purchase was owned up by other persons and the assessee was shown only as a facilitator, so the cash could not be taxed in his hands. Commission income was also deleted in the Prateek Bansal gold transaction because Bansal admitted the transaction and its profit, and there was no material for a separate commission to the assessee. For the seized 2 kg gold, ownership remained unclear; verification from the Enforcement Directorate was directed before deciding whether it was assessable as commission in the assessee's hands or in the company's hands.
Protective addition failed where the cash allegedly routed for gold purchase was owned up by other persons and the assessee was shown only as a facilitator, so the cash could not be taxed in his hands. Commission income was also deleted in the Prateek Bansal gold transaction because Bansal admitted the transaction and its profit, and there was no material for a separate commission to the assessee. For the seized 2 kg gold, ownership remained unclear; verification from the Enforcement Directorate was directed before deciding whether it was assessable as commission in the assessee's hands or in the company's hands.
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