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...
In a charitable institution's assessment, the Tribunal held that application of current-year income and accumulated funds, as separately disclosed in the return and Form 10B and verified in scrutiny, could not be disallowed on a supposed mismatch; once the Assessing Officer recorded that there was no difference between the two, the earlier prima facie adjustment under section 143(1) had no surviving basis and the claim was allowed in full. It also held that no fresh claim was being raised on appeal, so Goetze (India) was inapplicable. The final computation wrongly duplicated the same income components, inflating the taxable base; tax under section 115BBI and interest under sections 234B and 234C were consequential and had to be recomputed. The appeal was allowed.
In a charitable institution's assessment, the Tribunal held that application of current-year income and accumulated funds, as separately disclosed in the return and Form 10B and verified in scrutiny, could not be disallowed on a supposed mismatch; once the Assessing Officer recorded that there was no difference between the two, the earlier prima facie adjustment under section 143(1) had no surviving basis and the claim was allowed in full. It also held that no fresh claim was being raised on appeal, so Goetze (India) was inapplicable. The final computation wrongly duplicated the same income components, inflating the taxable base; tax under section 115BBI and interest under sections 234B and 234C were consequential and had to be recomputed. The appeal was allowed.
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