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...
The assessee's short-term capital gains from share trading were rightly treated as business income. Mere mention of shares as investments does not grant benefit under Circular No.4 of 2007. Separate account maintenance, delivery-based transactions, and acceptance of capital gains in preceding years were not sufficient to establish share trading as investments. The assessee was eligible for deduction u/s 80IC as the manufacturing unit was located in a notified area, fulfilling conditions. Disallowance of 20% of milk purchases was unjustified as expenses were duly debited, and net profit ratio was considered for assessment in subsequent years. The Tribunal allowed the assessee's claim, finding no justification for discrediting purchases on an ad hoc basis.
The assessee's short-term capital gains from share trading were rightly treated as business income. Mere mention of shares as investments does not grant benefit under Circular No.4 of 2007. Separate account maintenance, delivery-based transactions, and acceptance of capital gains in preceding years were not sufficient to establish share trading as investments. The assessee was eligible for deduction u/s 80IC as the manufacturing unit was located in a notified area, fulfilling conditions. Disallowance of 20% of milk purchases was unjustified as expenses were duly debited, and net profit ratio was considered for assessment in subsequent years. The Tribunal allowed the assessee's claim, finding no justification for discrediting purchases on an ad hoc basis.
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