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...
Territorial jurisdiction of the Assessing Officer must be exercised strictly in accordance with the jurisdictional directions and notifications issued under section 120, and concurrent jurisdiction arises only where specifically conferred. On the facts, the assessee's business and return particulars were at Kolkata, no Patna branch was shown, and the PAN tagging to Patna was found to be an error; the notice issued by the Patna officer was therefore without jurisdiction. The Tribunal held that the notice under section 143(2) and the consequential assessments were void, and the appeals were allowed with the assessment orders quashed.
Territorial jurisdiction of the Assessing Officer must be exercised strictly in accordance with the jurisdictional directions and notifications issued under section 120, and concurrent jurisdiction arises only where specifically conferred. On the facts, the assessee's business and return particulars were at Kolkata, no Patna branch was shown, and the PAN tagging to Patna was found to be an error; the notice issued by the Patna officer was therefore without jurisdiction. The Tribunal held that the notice under section 143(2) and the consequential assessments were void, and the appeals were allowed with the assessment orders quashed.
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