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...
Computer software acquired by the assessee was held to fall within the depreciable block of assets for computers including computer software, so depreciation had to be allowed at that rate and not as a business or commercial right under the intangible asset head. On section 14A read with Rule 8D, the Tribunal accepted the assessee's own disallowance on the facts, noting no dividend income from equity investments and only nominal exempt LLP profit, and restricted the disallowance to the suo motu amount. For MAT under section 115JB, it followed Vireet Investment and held that a Rule 8D disallowance does not enter book profit, so the addition was deleted and interest was to be recomputed consequentially.
Computer software acquired by the assessee was held to fall within the depreciable block of assets for computers including computer software, so depreciation had to be allowed at that rate and not as a business or commercial right under the intangible asset head. On section 14A read with Rule 8D, the Tribunal accepted the assessee's own disallowance on the facts, noting no dividend income from equity investments and only nominal exempt LLP profit, and restricted the disallowance to the suo motu amount. For MAT under section 115JB, it followed Vireet Investment and held that a Rule 8D disallowance does not enter book profit, so the addition was deleted and interest was to be recomputed consequentially.
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