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...
Cancellation of redemption certificate - validity of SCN - power of review - The contentions raised that the redemption certificate is final order, which can be reviewed under Section 16 of the Act is untenable and the redemption certificates issued based on the informations furnished by the petitioner, can never be construed as an order issued after adjudication for the purpose of exercise of power of review and therefore, the impugned show cause notice is issued, based on the report submitted by the Director of Revenue Intelligence, which is a fresh cause of action and more so, in respect of the documents furnished by the petitioner for the purpose of getting a redemption certificate and thus, such illegality or irregularity if any noticed, is to be proceeded with by following the procedures as contemplated under law. - HC
Cancellation of redemption certificate - validity of SCN - power of review - The contentions raised that the redemption certificate is final order, which can be reviewed under Section 16 of the Act is untenable and the redemption certificates issued based on the informations furnished by the petitioner, can never be construed as an order issued after adjudication for the purpose of exercise of power of review and therefore, the impugned show cause notice is issued, based on the report submitted by the Director of Revenue Intelligence, which is a fresh cause of action and more so, in respect of the documents furnished by the petitioner for the purpose of getting a redemption certificate and thus, such illegality or irregularity if any noticed, is to be proceeded with by following the procedures as contemplated under law. - HC
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