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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Rejection of approvals u/s 80G - approval application filed belatedly - The Tribunal noted that the CBDT had extended deadlines for filing applications for registration or approval in light of genuine hardships faced by charitable entities. This was a significant consideration, indicating a recognition of practical difficulties and an intent to mitigate them. The Tribunal held that the timelines prescribed under clause (iii) of the first proviso to section 80G(5) should be treated as directory rather than mandatory, especially in light of the transitional nature of amendments introduced by the Taxation and Other Laws (Relaxation and Amendment of Certain Provisions) Act, 2020. (TOLA)
Rejection of approvals u/s 80G - approval application filed belatedly - The Tribunal noted that the CBDT had extended deadlines for filing applications for registration or approval in light of genuine hardships faced by charitable entities. This was a significant consideration, indicating a recognition of practical difficulties and an intent to mitigate them. The Tribunal held that the timelines prescribed under clause (iii) of the first proviso to section 80G(5) should be treated as directory rather than mandatory, especially in light of the transitional nature of amendments introduced by the Taxation and Other Laws (Relaxation and Amendment of Certain Provisions) Act, 2020. (TOLA)
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