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...
Revision u/s 263 - unexplained cash deposit during the demonization period - The tribunal noted that the AO had conducted an adequate inquiry into the assessee's cash deposits, purchases, and sales, and had accepted the return of income after verification. It was found that the PCIT's order u/s 263 was based on re-evaluation of the same material already considered by the AO without any new evidence or inquiry that justified a revision u/s 263. - The ITAT concluded that the AO's order was not erroneous nor prejudicial to the interest of the revenue.
Revision u/s 263 - unexplained cash deposit during the demonization period - The tribunal noted that the AO had conducted an adequate inquiry into the assessee's cash deposits, purchases, and sales, and had accepted the return of income after verification. It was found that the PCIT's order u/s 263 was based on re-evaluation of the same material already considered by the AO without any new evidence or inquiry that justified a revision u/s 263. - The ITAT concluded that the AO's order was not erroneous nor prejudicial to the interest of the revenue.
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