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...
Additions for alleged unaccounted consideration in real-estate transactions require cogent, reliable and transaction-specific evidence of actual cash receipt or payment. Differing internal price references, ERP capabilities, employee statements, WhatsApp communications and an unsupported discount-based estimation cannot establish suppressed sale consideration without purchaser-wise proof, cash records, receipts, money trail or parallel books. Estimation may quantify undisclosed income only after its existence is established. Third-party loose sheets primarily attract statutory presumptions against their possessor; corroboration of recorded cheque payments does not prove an alleged cash component. Denial of cross-examination of the sheet's author is procedurally defective. Registered conveyances, books and banking trails remain effective affirmative evidence unless displaced by cogent material.
Additions for alleged unaccounted consideration in real-estate transactions require cogent, reliable and transaction-specific evidence of actual cash receipt or payment. Differing internal price references, ERP capabilities, employee statements, WhatsApp communications and an unsupported discount-based estimation cannot establish suppressed sale consideration without purchaser-wise proof, cash records, receipts, money trail or parallel books. Estimation may quantify undisclosed income only after its existence is established. Third-party loose sheets primarily attract statutory presumptions against their possessor; corroboration of recorded cheque payments does not prove an alleged cash component. Denial of cross-examination of the sheet's author is procedurally defective. Registered conveyances, books and banking trails remain effective affirmative evidence unless displaced by cogent material.
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