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 7 admission requires established financial debt and default, not precise interest quantification, while post-suspension defaults remain action...
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Directly relevant additional evidence supporting commission paid to daily deposit collection agents was admitted because the lower authorities had not examined it, and the commission disallowance was remanded for fresh consideration. Interest estimated on non-performing loans to members was deleted because income from credit facilities provided by a co-operative society to its members qualified for deduction under section 80P(2)(a)(i), rendering the addition revenue neutral. Interest estimated by applying a uniform rate across housing, mortgage, personal, deposit-backed and overdraft loans was also deleted because those loan categories carried differential rates and the resulting enhanced income would qualify for the same deduction. The appeal was partly allowed.
Directly relevant additional evidence supporting commission paid to daily deposit collection agents was admitted because the lower authorities had not examined it, and the commission disallowance was remanded for fresh consideration. Interest estimated on non-performing loans to members was deleted because income from credit facilities provided by a co-operative society to its members qualified for deduction under section 80P(2)(a)(i), rendering the addition revenue neutral. Interest estimated by applying a uniform rate across housing, mortgage, personal, deposit-backed and overdraft loans was also deleted because those loan categories carried differential rates and the resulting enhanced income would qualify for the same deduction. The appeal was partly allowed.
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