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...
Form No. 10BB filing for exemption of an approved educational institution was treated as procedural and directory, not mandatory, where the audit report had been uploaded and was available when the return was processed and the return was filed within the extended due date; the rejection of the exemption claim was therefore set aside and the matter remitted for fresh consideration, including the assessee's condonation application if produced. The Tribunal also held that, if exemption is ultimately denied, income must be computed on commercial principles, expenditure cannot be disallowed as a prima facie adjustment under section 143(1), and the entire receipts cannot be assessed as income.
Form No. 10BB filing for exemption of an approved educational institution was treated as procedural and directory, not mandatory, where the audit report had been uploaded and was available when the return was processed and the return was filed within the extended due date; the rejection of the exemption claim was therefore set aside and the matter remitted for fresh consideration, including the assessee's condonation application if produced. The Tribunal also held that, if exemption is ultimately denied, income must be computed on commercial principles, expenditure cannot be disallowed as a prima facie adjustment under section 143(1), and the entire receipts cannot be assessed as income.
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