Jurisdictional validity of revision notices: incorrect official capacity and mere change of opinion invalidate revision of property income assessments...
Bogus-purchase additions are limited to embedded profit where corresponding sales are accepted, while accommodation-entry information can support reas...
Section 115BBI applies only to income having the statutory character of specified income; an electronic-return reporting or computational mismatch does not create that character. Income validly accumulated for charitable purposes in an earlier year and applied during the relevant year remains outside that provision unless conditions governing the accumulation were breached or the income otherwise became specified income. Where return schedules and a revised audit report disclose the available accumulation and its application, section 143(1) processing cannot selectively rely on an omitted Schedule A entry while disregarding corresponding disclosures. The adjustment treating the applied accumulation as specified income was deleted.
Section 115BBI applies only to income having the statutory character of specified income; an electronic-return reporting or computational mismatch does not create that character. Income validly accumulated for charitable purposes in an earlier year and applied during the relevant year remains outside that provision unless conditions governing the accumulation were breached or the income otherwise became specified income. Where return schedules and a revised audit report disclose the available accumulation and its application, section 143(1) processing cannot selectively rely on an omitted Schedule A entry while disregarding corresponding disclosures. The adjustment treating the applied accumulation as specified income was deleted.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
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