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...
Penalty u/s 271(1)(c) was imposed for disallowance of depreciation on non-compete fees. The CIT(A) relied on Sharp Business System [2012 (11) TMI 324 - Delhi High Court], which is under challenge before the Supreme Court. Pepsico India Holding Pvt. Ltd. [2024 (4) TMI 1154 - Delhi High Court] allowed depreciation on non-compete fees after considering Sharp Business System. Different High Courts have divergent views on allowability of depreciation on non-compete fees, and the matter is pending before the Supreme Court. Considering the contentious issue, provisions of Section 271(1)(c) cannot be attracted. Assessee's appeal allowed.
Penalty u/s 271(1)(c) was imposed for disallowance of depreciation on non-compete fees. The CIT(A) relied on Sharp Business System [2012 (11) TMI 324 - Delhi High Court], which is under challenge before the Supreme Court. Pepsico India Holding Pvt. Ltd. [2024 (4) TMI 1154 - Delhi High Court] allowed depreciation on non-compete fees after considering Sharp Business System. Different High Courts have divergent views on allowability of depreciation on non-compete fees, and the matter is pending before the Supreme Court. Considering the contentious issue, provisions of Section 271(1)(c) cannot be attracted. Assessee's appeal allowed.
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