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...
Alleged bogus purchases could not justify an ad hoc gross profit addition where the suppliers' non-filing of returns was the only adverse feature, the purchases were recorded in the books, and no contrary material disproved them; the gross profit-based addition was deleted. On alleged unaccounted sales, only the profit element could be taxed, so the Tribunal sustained addition at a net profit rate of 4% rather than taxing the full sale proceeds. Cash entry-fee receipts were extrapolated from a short period, so the addition was restricted to 25%. Separate unexplained expenditure was telescoped against the estimated undisclosed income and deleted, and section 69C could not apply to recorded purchases paid through banking channels.
Alleged bogus purchases could not justify an ad hoc gross profit addition where the suppliers' non-filing of returns was the only adverse feature, the purchases were recorded in the books, and no contrary material disproved them; the gross profit-based addition was deleted. On alleged unaccounted sales, only the profit element could be taxed, so the Tribunal sustained addition at a net profit rate of 4% rather than taxing the full sale proceeds. Cash entry-fee receipts were extrapolated from a short period, so the addition was restricted to 25%. Separate unexplained expenditure was telescoped against the estimated undisclosed income and deleted, and section 69C could not apply to recorded purchases paid through banking channels.
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