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...
Undisclosed unaccounted expenditure and undisclosed income - By the connotation of "right person", it is meant the person who is liable to be taxed, according to law, with respect to a particular income. And that the expression "wrong person" is obviously used as an antithesis of the expression "right person" only. - We observe that this assessee is the "managing director" in the company. - And that it is this latter entity which the fact is engaged in all the business activity(ies) and has been assessed separately throughout. A company is very a body corporate and a distinct entity apart from its director. - CIT(A) has rightly deleted these twin additions in the assessee/individual's hands - AT
Undisclosed unaccounted expenditure and undisclosed income - By the connotation of "right person", it is meant the person who is liable to be taxed, according to law, with respect to a particular income. And that the expression "wrong person" is obviously used as an antithesis of the expression "right person" only. - We observe that this assessee is the "managing director" in the company. - And that it is this latter entity which the fact is engaged in all the business activity(ies) and has been assessed separately throughout. A company is very a body corporate and a distinct entity apart from its director. - CIT(A) has rightly deleted these twin additions in the assessee/individual's hands - AT
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