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...
Personal hearing notice issued to petitioner by Assistant Director (SRO) directing appearance before Additional Director (adjudicating authority). Additional Director's jurisdiction enhanced by notification dated 27.09.2018. Case transferred from Special Director to Additional Director due to pecuniary limits. Court held notification prospective, pending cases transferable to appropriate authority. Transfer from Special Director to Additional Director valid as per FEMA provisions for cases between Rs.10-25 crores, petitioner's case involving Rs.11.27 crores. No writ entertainable against show cause notice unless issued by incompetent authority or malafides alleged. Court found transfer valid u/s 16(1), FEMA Act. Writ petitions dismissed.
Personal hearing notice issued to petitioner by Assistant Director (SRO) directing appearance before Additional Director (adjudicating authority). Additional Director's jurisdiction enhanced by notification dated 27.09.2018. Case transferred from Special Director to Additional Director due to pecuniary limits. Court held notification prospective, pending cases transferable to appropriate authority. Transfer from Special Director to Additional Director valid as per FEMA provisions for cases between Rs.10-25 crores, petitioner's case involving Rs.11.27 crores. No writ entertainable against show cause notice unless issued by incompetent authority or malafides alleged. Court found transfer valid u/s 16(1), FEMA Act. Writ petitions dismissed.
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