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 260A confines High Court interference with Tribunal findings on rejection of books, income estimation and fee refunds to cases of perversity, lack of evidentiary support or legal error. Where seized material, account books and submissions require factual examination, alternative computations do not themselves create a substantial question of law. Once books are rejected, income and allowable fee refunds may be determined by estimation. The Tribunal may examine the basis and extent of fee-refund relief when the Revenue challenges that relief and the assessee files a cross-objection concerning the sustained addition; this remains within its appellate jurisdiction.
Section 260A confines High Court interference with Tribunal findings on rejection of books, income estimation and fee refunds to cases of perversity, lack of evidentiary support or legal error. Where seized material, account books and submissions require factual examination, alternative computations do not themselves create a substantial question of law. Once books are rejected, income and allowable fee refunds may be determined by estimation. The Tribunal may examine the basis and extent of fee-refund relief when the Revenue challenges that relief and the assessee files a cross-objection concerning the sustained addition; this remains within its appellate jurisdiction.
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