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 Tribunal found the reassessment proceedings to be invalid due to the non-application of mind by the AO and lack of valid approval as mandated by law. Specifically, the court noted that objections filed by the assessee were not disposed of in accordance with legal requirements, and the sanction under section 151 of the Act did not bear the signature of the PCIT, rendering the initiation of reassessment proceedings invalid.
Reopening of assessment u/s 147 - The Tribunal found the reassessment proceedings to be invalid due to the non-application of mind by the AO and lack of valid approval as mandated by law. Specifically, the court noted that objections filed by the assessee were not disposed of in accordance with legal requirements, and the sanction under section 151 of the Act did not bear the signature of the PCIT, rendering the initiation of reassessment proceedings invalid.
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