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...
Transfer pricing adjustments for sales to an associated enterprise were found unsustainable where abnormal business conditions followed the shutdown of the assessee's main customer, because benchmarking had to reflect the extraordinary circumstances and the actual downstream use of the goods. Business expenditure was treated as deductible going concern expenditure: the outlay was incurred to keep trading operations running, and an ad hoc disallowance based on assumed future expansion was rejected. A sale of plant and machinery was held to be an itemised asset sale, not a slump sale, because values were assigned asset-wise and there was no transfer of the undertaking as a whole.
Transfer pricing adjustments for sales to an associated enterprise were found unsustainable where abnormal business conditions followed the shutdown of the assessee's main customer, because benchmarking had to reflect the extraordinary circumstances and the actual downstream use of the goods. Business expenditure was treated as deductible going concern expenditure: the outlay was incurred to keep trading operations running, and an ad hoc disallowance based on assumed future expansion was rejected. A sale of plant and machinery was held to be an itemised asset sale, not a slump sale, because values were assigned asset-wise and there was no transfer of the undertaking as a whole.
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