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...
Prima facie substance in a limitation challenge to reassessment, coupled with a high-pitched assessment, warranted unconditional protection from recovery pending appeal. The stay-rejection order failed to address the taxpayer's material contentions solely because an appeal was pending. Financial capacity could not be inferred from gross turnover without considering returned income. The rejection was set aside, recovery of the reassessment demand was stayed until appeal disposal, and the appellate authority was to determine the appeal independently and expeditiously on its merits.
Prima facie substance in a limitation challenge to reassessment, coupled with a high-pitched assessment, warranted unconditional protection from recovery pending appeal. The stay-rejection order failed to address the taxpayer's material contentions solely because an appeal was pending. Financial capacity could not be inferred from gross turnover without considering returned income. The rejection was set aside, recovery of the reassessment demand was stayed until appeal disposal, and the appellate authority was to determine the appeal independently and expeditiously on its merits.
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