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...
Reopening of assessment u/s 147 - The High Court observed that, the expression “accommodation entry” and “bogus financial transaction” in the recorded reasons are not reason for formation of reasonable belief but are conclusions. - The HC further observed that it is also not clear whether the statement of “accommodation entry provider” is recorded U/s 132(4) or Section 133A, inasmuch as, a statement recorded U/s 133A has no evidentiary value. - The High Court quashed the proceedings / notice since the Assessment Order is passed on pure guess work without any relevant material which is contrary to mandates of Section 144 dealing with Best Judgment Assessment.
Reopening of assessment u/s 147 - The High Court observed that, the expression “accommodation entry” and “bogus financial transaction” in the recorded reasons are not reason for formation of reasonable belief but are conclusions. - The HC further observed that it is also not clear whether the statement of “accommodation entry provider” is recorded U/s 132(4) or Section 133A, inasmuch as, a statement recorded U/s 133A has no evidentiary value. - The High Court quashed the proceedings / notice since the Assessment Order is passed on pure guess work without any relevant material which is contrary to mandates of Section 144 dealing with Best Judgment Assessment.
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