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...
Professional income cannot be assessed by treating an entire doctor's gross receipts as net income solely because no return was filed. For a reasonable assessment, the taxpayer's offer of 50% of receipts as income, tax payment on that basis, and Revenue acceptance of the same approach in subsequent years for the identical profession were relevant, although they did not establish formal eligibility for presumptive taxation under section 44ADA for the relevant year. The Tribunal did not decide whether section 44ADA could be claimed without filing a return. Professional income was restricted to 50% of gross receipts; unpressed grounds were dismissed.
Professional income cannot be assessed by treating an entire doctor's gross receipts as net income solely because no return was filed. For a reasonable assessment, the taxpayer's offer of 50% of receipts as income, tax payment on that basis, and Revenue acceptance of the same approach in subsequent years for the identical profession were relevant, although they did not establish formal eligibility for presumptive taxation under section 44ADA for the relevant year. The Tribunal did not decide whether section 44ADA could be claimed without filing a return. Professional income was restricted to 50% of gross receipts; unpressed grounds were dismissed.
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