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...
Validity of Reopening of assessment - disallowance of expenditure being the inflated cost of fuels - information from the Directorate of Revenue Intelligence (DRI) relied upon - The Tribunal noted that, the basis for the reopening, a DRI show cause notice, was quashed by the competent authority/ CESTAT, making the reassessment unsustainable. The ITAT upheld the order of CIT(A) deleting the additions as the determination made by the AO in any case is un-sustainable being sans foundation/substantive material.
Validity of Reopening of assessment - disallowance of expenditure being the inflated cost of fuels - information from the Directorate of Revenue Intelligence (DRI) relied upon - The Tribunal noted that, the basis for the reopening, a DRI show cause notice, was quashed by the competent authority/ CESTAT, making the reassessment unsustainable. The ITAT upheld the order of CIT(A) deleting the additions as the determination made by the AO in any case is un-sustainable being sans foundation/substantive material.
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