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...
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Reassessment notices issued to deceased assessees are invalid because the legal-representative provisions permit either continuation of proceedings started during the assessee's lifetime or fresh proceedings directly against the legal representative; they do not permit a notice to be issued in the deceased person's name and later continued against an heir. Consequently, reassessment founded on such a notice is unsustainable and must be quashed. Where jurisdiction fails at the notice stage, challenges to the underlying additions need not be adjudicated and remain open.
Reassessment notices issued to deceased assessees are invalid because the legal-representative provisions permit either continuation of proceedings started during the assessee's lifetime or fresh proceedings directly against the legal representative; they do not permit a notice to be issued in the deceased person's name and later continued against an heir. Consequently, reassessment founded on such a notice is unsustainable and must be quashed. Where jurisdiction fails at the notice stage, challenges to the underlying additions need not be adjudicated and remain open.
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