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...
Section 10(4)(ii) exempts interest on NRE deposits where an individual is either a person resident outside India under FEMA or is permitted by the RBI to maintain the NRE account. A change in residential status is therefore not conclusive of exemption eligibility. Continued authority under the applicable RBI/FEMA framework to maintain NRE deposits requires factual verification. Eligibility must be examined on this limited basis, with an opportunity of hearing, without reopening unrelated issues.
Section 10(4)(ii) exempts interest on NRE deposits where an individual is either a person resident outside India under FEMA or is permitted by the RBI to maintain the NRE account. A change in residential status is therefore not conclusive of exemption eligibility. Continued authority under the applicable RBI/FEMA framework to maintain NRE deposits requires factual verification. Eligibility must be examined on this limited basis, with an opportunity of hearing, without reopening unrelated issues.
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