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...
Valuation of consideration for a limited patent-use licence turned on materially divergent expert reports applying an internationally accepted cost approach and a substantially higher departmental valuation. Neither valuation position was accepted in full. A lump-sum estimate was adopted in the interest of justice, expressly without precedential effect, fixing the amount attributable to the limited patent-use right at USD 900,000. Consequential computation was directed in accordance with law, and the appeal was partly allowed to that extent.
Valuation of consideration for a limited patent-use licence turned on materially divergent expert reports applying an internationally accepted cost approach and a substantially higher departmental valuation. Neither valuation position was accepted in full. A lump-sum estimate was adopted in the interest of justice, expressly without precedential effect, fixing the amount attributable to the limited patent-use right at USD 900,000. Consequential computation was directed in accordance with law, and the appeal was partly allowed to that extent.
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