Additional evidence in departmental appeals may include show-cause-notice material without introducing a new case where it merely corroborates existin...
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...
Interest on bank fixed deposits held in a trust's name constitutes the trust's income, even where the funds are intended for Self-Help Groups. Corpus exemption requires a specific written direction from the donor; correspondence allowing distribution of refunded funds did not direct that deposit interest form part of the corpus. A later obligation to allocate funds to Self-Help Groups is application of income, not diversion at source. The trust cannot claim tax deducted at source credit while excluding the interest from revenue receipts. The interest was taxable as revenue income, and its addition was affirmed.
Interest on bank fixed deposits held in a trust's name constitutes the trust's income, even where the funds are intended for Self-Help Groups. Corpus exemption requires a specific written direction from the donor; correspondence allowing distribution of refunded funds did not direct that deposit interest form part of the corpus. A later obligation to allocate funds to Self-Help Groups is application of income, not diversion at source. The trust cannot claim tax deducted at source credit while excluding the interest from revenue receipts. The interest was taxable as revenue income, and its addition was affirmed.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4894 
