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...
Rectification of mistake - ITAT has allows appeal on merit & dismissed the assessee’s cross objections as infructuous regarding re-opening of assessment. Assesse not challenged that order. After reversal of appeal by High court on merit assesse filed rectification application before Tribunal. High Court held that rectification application filed by the assessee was barred by the principle of finality, and to an extent the doctrine of merger. High Court further held that this is not apparent mistake or error warranting rectification.
Rectification of mistake - ITAT has allows appeal on merit & dismissed the assessee’s cross objections as infructuous regarding re-opening of assessment. Assesse not challenged that order. After reversal of appeal by High court on merit assesse filed rectification application before Tribunal. High Court held that rectification application filed by the assessee was barred by the principle of finality, and to an extent the doctrine of merger. High Court further held that this is not apparent mistake or error warranting rectification.
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