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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Assessee, a company paying taxes at fixed rate, filed claim for prior period depreciation. ITAT held allowance of prior period depreciation claim was tax neutral exercise, not resulting in revenue loss. Assessee entitled to claim unabsorbed depreciation of preceding year as depreciation of succeeding year u/s 32(2). Revisionary jurisdiction u/s 263 unwarranted as assessment order not erroneous causing prejudice to revenue. However, ITAT confirmed PCIT's order regarding non-examination of TDS on rent expenses by AO u/s 40(a)(ia), holding assessment order erroneous on this count. Appeal partly allowed.
Assessee, a company paying taxes at fixed rate, filed claim for prior period depreciation. ITAT held allowance of prior period depreciation claim was tax neutral exercise, not resulting in revenue loss. Assessee entitled to claim unabsorbed depreciation of preceding year as depreciation of succeeding year u/s 32(2). Revisionary jurisdiction u/s 263 unwarranted as assessment order not erroneous causing prejudice to revenue. However, ITAT confirmed PCIT's order regarding non-examination of TDS on rent expenses by AO u/s 40(a)(ia), holding assessment order erroneous on this count. Appeal partly allowed.
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