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...
Revision of an assessment for lack of inquiry requires an erroneous and prejudicial order, not merely a different view of matters examined during scrutiny. Where the Assessing Officer made inquiries into depreciation on fixed assets, commission paid to a non-resident, and deductions for employing new workmen, and applied mind to the responses, revision was not sustainable. The Principal Commissioner had identified neither a flaw in the assessee's replies nor a specific defect in the prescribed audit report. The revision order was quashed, and the tax appeal was dismissed because the Tribunal's findings disclosed no legal infirmity.
Revision of an assessment for lack of inquiry requires an erroneous and prejudicial order, not merely a different view of matters examined during scrutiny. Where the Assessing Officer made inquiries into depreciation on fixed assets, commission paid to a non-resident, and deductions for employing new workmen, and applied mind to the responses, revision was not sustainable. The Principal Commissioner had identified neither a flaw in the assessee's replies nor a specific defect in the prescribed audit report. The revision order was quashed, and the tax appeal was dismissed because the Tribunal's findings disclosed no legal infirmity.
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