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...
Actuarial deficit contributions made to an approved superannuation fund to align fund assets with actuarial liabilities are distinguished from ordinary annual or initial contributions. Because their purpose is to remedy an actuarial shortfall, they are not subject to the Rule 87 ceiling on annual contributions, preserving the fund's solvency. Similarly, contributions bridging actuarial liability and available assets in an approved gratuity fund are not ordinary annual contributions subject to the Rule 103 ceiling. Unless approval is formally withdrawn, the assessing authority must accept the fund's approved status and cannot, during assessment, question compliance with the Rules to restrict the deduction.
Actuarial deficit contributions made to an approved superannuation fund to align fund assets with actuarial liabilities are distinguished from ordinary annual or initial contributions. Because their purpose is to remedy an actuarial shortfall, they are not subject to the Rule 87 ceiling on annual contributions, preserving the fund's solvency. Similarly, contributions bridging actuarial liability and available assets in an approved gratuity fund are not ordinary annual contributions subject to the Rule 103 ceiling. Unless approval is formally withdrawn, the assessing authority must accept the fund's approved status and cannot, during assessment, question compliance with the Rules to restrict the deduction.
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