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...
Cash consideration receivable, whether as advance or otherwise, for transfer of immovable property falls within "specified sum" and is governed by section 269SS; the contention that section 269ST exclusively applied was rejected. However, penalty under section 271D could not be sustained for an assessment year in which no cash consideration was received. As the relevant receipts occurred in an earlier financial year, the penalty levied for AY 2017-18 was held invalid and deleted. The Tribunal also noted that part of the receipts preceded the amendment extending section 269SS to specified sums connected with immovable property transfers.
Cash consideration receivable, whether as advance or otherwise, for transfer of immovable property falls within "specified sum" and is governed by section 269SS; the contention that section 269ST exclusively applied was rejected. However, penalty under section 271D could not be sustained for an assessment year in which no cash consideration was received. As the relevant receipts occurred in an earlier financial year, the penalty levied for AY 2017-18 was held invalid and deleted. The Tribunal also noted that part of the receipts preceded the amendment extending section 269SS to specified sums connected with immovable property transfers.
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