Concessional corporate tax option under section 115BAA survives procedural documentary lapses when statutory compliance and earlier exercise are estab...
Penny-stock additions require transaction-specific evidence; general investigation material alone cannot establish undisclosed income or accommodation...
Transfer pricing comparability prioritises reliable external CUPs and foreign-currency LIBOR benchmarks for exports, borrowings and delayed receivable...
Section 153C satisfaction and seized electronic records sustained unexplained-investment addition, subject to proportionate ownership-share verificati...
Denial of exemption u/s 10(23C)(iiiad), addition of unexplained cash credits u/s 69A. Registration granted u/s 12AA from 23-02-2019 indicating trust not exclusively engaged in education. Assessing Officer treated trust as Association of Persons, rendering income from cash deposits taxable due to lack of registration u/s 12A. Assessee's contention regarding cash deposits relating to hostel receipts from third parties not substantiated by documentary evidence or formal agreement. Income from cash deposits to be considered in hands of trust in absence of supporting documentation. Commissioner of Income Tax (Appeals) directed to re-examine classification as Association of Persons and tax implications, ensuring income without third-party attribution is taxed in hands of trust. Order of Commissioner of Income Tax (Appeals) set aside, matter remitted for fresh adjudication as per law after considering facts, evidence, and submissions. Appeal allowed for statistical purposes.
Denial of exemption u/s 10(23C)(iiiad), addition of unexplained cash credits u/s 69A. Registration granted u/s 12AA from 23-02-2019 indicating trust not exclusively engaged in education. Assessing Officer treated trust as Association of Persons, rendering income from cash deposits taxable due to lack of registration u/s 12A. Assessee's contention regarding cash deposits relating to hostel receipts from third parties not substantiated by documentary evidence or formal agreement. Income from cash deposits to be considered in hands of trust in absence of supporting documentation. Commissioner of Income Tax (Appeals) directed to re-examine classification as Association of Persons and tax implications, ensuring income without third-party attribution is taxed in hands of trust. Order of Commissioner of Income Tax (Appeals) set aside, matter remitted for fresh adjudication as per law after considering facts, evidence, and submissions. Appeal allowed for statistical purposes.
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