Appellate enhancement limits protect against new income sources, while documented credits and prior-year investments resist unexplained-income additio...
Capital-gains exemption for charitable trusts extends to qualifying fixed deposits, while unrecoverable TDS write-offs may constitute income applicati...
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Revision u/s 263 - addition on account of notional interest @10% on deposit - The High court upheld the concurrent findings of the ITAT and the CIT(A) that no notional interest income accrued to the assessee, after its amalgamation, as per the loan agreement clause. - This decision was based on the principle that income cannot be taxed on a purely notional basis; it must either accrue as per agreement terms or be received by the assessee.
Revision u/s 263 - addition on account of notional interest @10% on deposit - The High court upheld the concurrent findings of the ITAT and the CIT(A) that no notional interest income accrued to the assessee, after its amalgamation, as per the loan agreement clause. - This decision was based on the principle that income cannot be taxed on a purely notional basis; it must either accrue as per agreement terms or be received by the assessee.
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