Reasoned rectification orders require consideration of expenditure disclosed in income-tax returns, preventing revision based on incomplete income com...
Modified returns after business reorganisations cannot trigger fresh scrutiny once the original assessment was complete, invalidating related transfer...
Third-party loose sheets require reliable nexus before supporting unexplained expenditure additions; presumptions do not establish payer identity or o...
TNMM comparability using audited accounts and working-capital adjustments can eliminate unwarranted transfer-pricing additions where verified margins ...
Gross-profit additions on disputed purchases require reasoned appellate determination; disclosed claims alone do not support inaccurate-particulars pe...
Limitation after transfer-pricing remand: fresh TPO reference did not extend the assessment deadline, rendering the consequential assessment time-barr...
Interim judicial restraint on tax deduction prevents default, while supporting reasonable cause and penalty deletion for foreign-leg LFC reimbursement...
Palmolein classification defeated the crude-oil concession; material misdeclaration sustained recovery and confiscation, while separate false-document...
Charitable purpose is not defeated where sponsorship receipts from a women's marathon have a real and proximate nexus with objects of women's health, fitness, awareness and empowerment. The proviso to section 2(15) requires proof that the recipient's activity intrinsically operates as trade, commerce or business; sponsors' advertising treatment, receipt magnitude or surplus alone is insufficient. The 20% receipts formulation did not apply for the relevant assessment year, and exceeding the applicable monetary threshold could not replace that proof. Consequently, section 13(8) could not deny exemption under sections 11 and 12. Form No. 10B furnished during assessment cured an erroneous original exemption form where audit was completed before return filing and eligibility was examined on merits; the lapse was procedural.
Charitable purpose is not defeated where sponsorship receipts from a women's marathon have a real and proximate nexus with objects of women's health, fitness, awareness and empowerment. The proviso to section 2(15) requires proof that the recipient's activity intrinsically operates as trade, commerce or business; sponsors' advertising treatment, receipt magnitude or surplus alone is insufficient. The 20% receipts formulation did not apply for the relevant assessment year, and exceeding the applicable monetary threshold could not replace that proof. Consequently, section 13(8) could not deny exemption under sections 11 and 12. Form No. 10B furnished during assessment cured an erroneous original exemption form where audit was completed before return filing and eligibility was examined on merits; the lapse was procedural.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4897 
