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...
The extended period beyond six assessment years for a search assessment under the fourth proviso to section 153A(1) applies only where material available to the Assessing Officer shows escaped income represented by a stipulated asset of the required value. Alleged on-money receipts from project buyers, without a finding that those receipts were represented by such an asset, do not meet that condition. Assessments initiated beyond the six-year period on that basis were void ab initio, and the consequential reassessment orders for the relevant years were invalid.
The extended period beyond six assessment years for a search assessment under the fourth proviso to section 153A(1) applies only where material available to the Assessing Officer shows escaped income represented by a stipulated asset of the required value. Alleged on-money receipts from project buyers, without a finding that those receipts were represented by such an asset, do not meet that condition. Assessments initiated beyond the six-year period on that basis were void ab initio, and the consequential reassessment orders for the relevant years were invalid.
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