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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The reassessment proceeding shall be deemed completed only upon communication of the impugned assessment order to the assessee, not merely when the order was passed. The order cannot be considered passed unless pronounced, published, or the affected party has means of knowing it. Keeping the signed order in file without communicating is insufficient. The reassessment proceeding for AY 2003-2004 was completed on 05-04-2007 when the order was served, beyond the limitation period prescribed u/s 153(2). Availability of statutory appeal does not bar entertaining a writ petition under Article 226 in certain exceptions like violation of statutory provisions, natural justice, lack of jurisdiction, or pure legal controversy. The impugned assessment orders were quashed for violating section 153(2) of the Income Tax Act, 1961.
The reassessment proceeding shall be deemed completed only upon communication of the impugned assessment order to the assessee, not merely when the order was passed. The order cannot be considered passed unless pronounced, published, or the affected party has means of knowing it. Keeping the signed order in file without communicating is insufficient. The reassessment proceeding for AY 2003-2004 was completed on 05-04-2007 when the order was served, beyond the limitation period prescribed u/s 153(2). Availability of statutory appeal does not bar entertaining a writ petition under Article 226 in certain exceptions like violation of statutory provisions, natural justice, lack of jurisdiction, or pure legal controversy. The impugned assessment orders were quashed for violating section 153(2) of the Income Tax Act, 1961.
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