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...
Section 7 admission requires established financial debt and default, not precise interest quantification, while post-suspension defaults remain action...
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Estimation of income - bogus purchases - The Tribunal addressed various issues, including the validity of the reopening of assessment, the genuineness of purchases, calculation of the profit element, and determination of the gross profit rate. It found that the purchases were reconciled with sales, indicating their genuineness. Relying on judicial precedents, the Tribunal concluded that only the profit element of the alleged bogus purchases should be assessed. It accepted the industry-standard gross profit rate of 3% for diamond trading and modified the CIT(A)'s order accordingly, restricting the addition to the profit element.
Estimation of income - bogus purchases - The Tribunal addressed various issues, including the validity of the reopening of assessment, the genuineness of purchases, calculation of the profit element, and determination of the gross profit rate. It found that the purchases were reconciled with sales, indicating their genuineness. Relying on judicial precedents, the Tribunal concluded that only the profit element of the alleged bogus purchases should be assessed. It accepted the industry-standard gross profit rate of 3% for diamond trading and modified the CIT(A)'s order accordingly, restricting the addition to the profit element.
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