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...
Reopening of assessment u/s 147 - reopening beyond the period of four years - Merely because while framing assessment for the subsequent year, the AO noticed certain irregularity in the claim by itself would not be sufficient to satisfy requirements of the proviso to Section 147 - It is possible that the specific angle of the depreciation earlier claimed to be set off against the income of the current year of the eligible business may not have been in the mind of the Assessing Officer. - Notice quashed - HC
Reopening of assessment u/s 147 - reopening beyond the period of four years - Merely because while framing assessment for the subsequent year, the AO noticed certain irregularity in the claim by itself would not be sufficient to satisfy requirements of the proviso to Section 147 - It is possible that the specific angle of the depreciation earlier claimed to be set off against the income of the current year of the eligible business may not have been in the mind of the Assessing Officer. - Notice quashed - HC
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