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...
Schemes of merger and demerger approved by NCLT - jurisdiction of AO - None of the decisions cited by the learned senior advocate held that the revenue does not have an authority to compute the tax liability of the assessee in pursuance to the scheme of corporate reorganization approved by the National Company Law Tribunal. Further, the object of the representation before the National Company Law Tribunal is only with respect to the scheme, if it is to defraud the revenue. Naturally, any scheme which is framed for with the object of defrauding the revenue cannot be approved by the NCLT. - AT
Schemes of merger and demerger approved by NCLT - jurisdiction of AO - None of the decisions cited by the learned senior advocate held that the revenue does not have an authority to compute the tax liability of the assessee in pursuance to the scheme of corporate reorganization approved by the National Company Law Tribunal. Further, the object of the representation before the National Company Law Tribunal is only with respect to the scheme, if it is to defraud the revenue. Naturally, any scheme which is framed for with the object of defrauding the revenue cannot be approved by the NCLT. - AT
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