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...
Validity of reassessment proceedings - Reason to believe - The tribunal found that there was sufficient "reason to believe" that income had escaped assessment due to the admissions made during the survey. They referenced section 147 and noted that reassessment was justified based on the prima facie evidence available from the survey. - The tribunal concluded that the notices under section 148 were correctly issued, considering the sworn statements and other corroborating material from the survey, such as the admission of bogus purchases.
Validity of reassessment proceedings - Reason to believe - The tribunal found that there was sufficient "reason to believe" that income had escaped assessment due to the admissions made during the survey. They referenced section 147 and noted that reassessment was justified based on the prima facie evidence available from the survey. - The tribunal concluded that the notices under section 148 were correctly issued, considering the sworn statements and other corroborating material from the survey, such as the admission of bogus purchases.
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