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 - Reasons to believe - The ITAT thoroughly examined the reasons recorded by the AO for re-opening the assessment and found that there was no new or tangible material available to justify the re-opening. It was established that the AO had already examined and allowed the assessee's claim of deduction under Section 80IB(10) during the original assessment proceedings after due application of mind. The Tribunal concluded that the re-opening of the assessment was solely based on a re-appraisal of the same material available during the original assessment, amounting to a review of the decision taken earlier, which is legally impermissible.
Reopening of assessment u/s 147 - Reasons to believe - The ITAT thoroughly examined the reasons recorded by the AO for re-opening the assessment and found that there was no new or tangible material available to justify the re-opening. It was established that the AO had already examined and allowed the assessee's claim of deduction under Section 80IB(10) during the original assessment proceedings after due application of mind. The Tribunal concluded that the re-opening of the assessment was solely based on a re-appraisal of the same material available during the original assessment, amounting to a review of the decision taken earlier, which is legally impermissible.
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