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...
Assessment u/s 153A - addition made in respect of completed assessment in absence of any incriminating material - The tribunal found that the additions made to the taxpayer’s income for these years were not backed by any incriminating evidence obtained during the search. Citing several precedents, including a Supreme Court ruling, the Tribunal noted that additions cannot be made for completed assessment years in the absence of incriminating material. Similar to the earlier years, the Tribunal observed that the additions were based solely on statements made under distress without any corroborating material evidence.
Assessment u/s 153A - addition made in respect of completed assessment in absence of any incriminating material - The tribunal found that the additions made to the taxpayer’s income for these years were not backed by any incriminating evidence obtained during the search. Citing several precedents, including a Supreme Court ruling, the Tribunal noted that additions cannot be made for completed assessment years in the absence of incriminating material. Similar to the earlier years, the Tribunal observed that the additions were based solely on statements made under distress without any corroborating material evidence.
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