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...
Pre-reassessment procedure requires the Assessing Officer to issue a show-cause notice, consider the taxpayer's reply and form only a prima facie view that income has escaped assessment. Absence of an oral hearing at that preliminary stage does not by itself invalidate the pre-reassessment order or consequential reassessment notice where a substantive opportunity remains available during reassessment. Information concerning unsecured loans and cash deposits may be considered collectively where intrinsically connected to the alleged escaped income; the genuineness of the loan is to be examined in reassessment. The reassessment must provide a meaningful personal hearing and consider further documents and explanations, with merits left open.
Pre-reassessment procedure requires the Assessing Officer to issue a show-cause notice, consider the taxpayer's reply and form only a prima facie view that income has escaped assessment. Absence of an oral hearing at that preliminary stage does not by itself invalidate the pre-reassessment order or consequential reassessment notice where a substantive opportunity remains available during reassessment. Information concerning unsecured loans and cash deposits may be considered collectively where intrinsically connected to the alleged escaped income; the genuineness of the loan is to be examined in reassessment. The reassessment must provide a meaningful personal hearing and consider further documents and explanations, with merits left open.
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