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...
Penalty u/s. 271D - Failure to record any satisfaction for initiating the said penalty proceedings by the A.O - Tribunal held that, the issue before us is no more resintegra in light of the judgment of the Hon’ble Supreme Court in the case of CIT Vs. Jai Laxmi Rice Mills Ambala City [2023 (10) TMI 707 - GUJARAT HIGH COURT], therefore, in the backdrop of our aforesaid deliberations, the penalty imposed by the Jt.CIT u/s. 271D of the Act cannot be sustained and is liable to be struck down for want of valid assumption of jurisdiction.
Penalty u/s. 271D - Failure to record any satisfaction for initiating the said penalty proceedings by the A.O - Tribunal held that, the issue before us is no more resintegra in light of the judgment of the Hon’ble Supreme Court in the case of CIT Vs. Jai Laxmi Rice Mills Ambala City [2023 (10) TMI 707 - GUJARAT HIGH COURT], therefore, in the backdrop of our aforesaid deliberations, the penalty imposed by the Jt.CIT u/s. 271D of the Act cannot be sustained and is liable to be struck down for want of valid assumption of jurisdiction.
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