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...
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Seeking review of order - error apparent on the face of record or not - The court acknowledged the existence of the amendment to Paragraph 9.3 of the Handbook of Procedures and recognized its relevance to the case. However, it concluded that the amendment had been duly considered in the earlier order, and there was no error apparent on the face of the record regarding its application. In line with the respondents' argument, the court emphasized that a review cannot be used as a disguised appeal. It cited a Supreme Court decision that cautioned against exceeding jurisdiction in review applications and reiterated the principle that a review cannot reevaluate evidence already considered in the main petition.
Seeking review of order - error apparent on the face of record or not - The court acknowledged the existence of the amendment to Paragraph 9.3 of the Handbook of Procedures and recognized its relevance to the case. However, it concluded that the amendment had been duly considered in the earlier order, and there was no error apparent on the face of the record regarding its application. In line with the respondents' argument, the court emphasized that a review cannot be used as a disguised appeal. It cited a Supreme Court decision that cautioned against exceeding jurisdiction in review applications and reiterated the principle that a review cannot reevaluate evidence already considered in the main petition.
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