Receipt of immovable property requires actual possession or enjoyment; redevelopment allotments exchanged for tenancy rights fall outside deemed incom...
Section 80P deduction covers Souharda credit societies, including qualifying surplus-deposit interest, subject to member KYC verification for cash dep...
Transfer-pricing benchmarking and capital-receipt principles sustained taxpayer relief, while unsupported property-advance write-offs remained disallo...
Rejection of audited books under section 145(3) requires specific defects in the accounts and cannot rest solely on non-compliance with sample third-party notices issued under section 133(6). Where the Assessing Officer verified the supplied particulars and the receipts of an HR outsourcing provider substantially comprised salary and statutory reimbursements as pass-through costs, treating total gross receipts as income and applying a fixed profit rate lacked a rational basis. The estimated addition was therefore arbitrary; deletion by the Commissioner (Appeals) was sustained and the Revenue's appeal was dismissed.
Rejection of audited books under section 145(3) requires specific defects in the accounts and cannot rest solely on non-compliance with sample third-party notices issued under section 133(6). Where the Assessing Officer verified the supplied particulars and the receipts of an HR outsourcing provider substantially comprised salary and statutory reimbursements as pass-through costs, treating total gross receipts as income and applying a fixed profit rate lacked a rational basis. The estimated addition was therefore arbitrary; deletion by the Commissioner (Appeals) was sustained and the Revenue's appeal was dismissed.
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