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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Competent sanction under section 151 is a substantive jurisdictional safeguard for reassessment. TOLA extended the authority under section 151(i) only until 30 June 2021; for notices issued in July 2022, approval from the higher authority under section 151(ii) was required. Approval by the Principal Commissioner was neither substantial compliance nor curable under section 292B, so the reassessment and consequential addition were annulled. Penalty for failure to obtain a tax audit requires proof of business activity and legally relevant turnover exceeding the prescribed threshold. Purchases, delivery-based sales and unproved derivative transactions could not establish turnover; consistent investment treatment and capital-gains disclosure also demonstrated reasonable cause. The audit penalty was deleted.
Competent sanction under section 151 is a substantive jurisdictional safeguard for reassessment. TOLA extended the authority under section 151(i) only until 30 June 2021; for notices issued in July 2022, approval from the higher authority under section 151(ii) was required. Approval by the Principal Commissioner was neither substantial compliance nor curable under section 292B, so the reassessment and consequential addition were annulled. Penalty for failure to obtain a tax audit requires proof of business activity and legally relevant turnover exceeding the prescribed threshold. Purchases, delivery-based sales and unproved derivative transactions could not establish turnover; consistent investment treatment and capital-gains disclosure also demonstrated reasonable cause. The audit penalty was deleted.
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