Embezzlement losses in charitable institutions remain allowable when misappropriation is established, irrecoverable, and not a specified-person benefi...
National long-distance undertaking status supports deduction where separately licensed infrastructure, resources, revenue, and expenditure establish c...
Agency reimbursement income follows contractual deposit-liability computation, while pending deposit collections do not constitute deemed-dividend loa...
Membership-consent thresholds for oppression petitions are satisfied by unchallenged voter-list consents, while unsupported forgery claims require pro...
Revisionary jurisdiction applies where a reassessment accepts non-taxability of accumulated interest without necessary inquiry or application of governing provisions, rendering it erroneous and prejudicial to Revenue interests and permitting fresh determination. Premature conversion of zero-coupon debentures into equity shares of ascertainable value can constitute constructive receipt of accumulated interest even under cash-basis accounting. Claiming tax-deducted-at-source credit for that interest is inconsistent with denying the underlying income. The capital-gains exclusion for conversion does not exempt embedded interest from taxation; once taxed, the interest forms part of the shares' cost basis, preventing double taxation on sale.
Revisionary jurisdiction applies where a reassessment accepts non-taxability of accumulated interest without necessary inquiry or application of governing provisions, rendering it erroneous and prejudicial to Revenue interests and permitting fresh determination. Premature conversion of zero-coupon debentures into equity shares of ascertainable value can constitute constructive receipt of accumulated interest even under cash-basis accounting. Claiming tax-deducted-at-source credit for that interest is inconsistent with denying the underlying income. The capital-gains exclusion for conversion does not exempt embedded interest from taxation; once taxed, the interest forms part of the shares' cost basis, preventing double taxation on sale.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
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