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...
Assessee surrendered allotment of flats, received refund from builder, and claimed long-term capital loss. Held: Assessee acquired 'right to acquire' flats, a capital asset. Surrender of this right constitutes transfer, attracting capital gains computation. Section 50C and 56(2)(X) inapplicable as transfer involved 'right', not land/building. Capital loss carry forward allowed. Penalty under 271(1)(c) not imposable for withdrawing expense claim voluntarily before confrontation by AO, as it would discourage return defect disclosure and violate fairness in tax administration when interest on differential tax paid. Assessee's honesty cannot attract penalties. ITAT allowed assessee's appeal.
Assessee surrendered allotment of flats, received refund from builder, and claimed long-term capital loss. Held: Assessee acquired 'right to acquire' flats, a capital asset. Surrender of this right constitutes transfer, attracting capital gains computation. Section 50C and 56(2)(X) inapplicable as transfer involved 'right', not land/building. Capital loss carry forward allowed. Penalty under 271(1)(c) not imposable for withdrawing expense claim voluntarily before confrontation by AO, as it would discourage return defect disclosure and violate fairness in tax administration when interest on differential tax paid. Assessee's honesty cannot attract penalties. ITAT allowed assessee's appeal.
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