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...
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The Income Tax Appellate Tribunal allowed the assessee's appeal and directed the Assessing Officer to permit the deduction of bad debts claimed u/s 37(1) of the Income Tax Act. The Tribunal held that the authorities below misunderstood the facts and failed to appreciate the prevailing business scenario. Venturing into diverse sectors is common for large corporate houses. The assessee's investment in the subsidiary was part of its business, and after a long gestation period, the question of it not being part of the assessee's business was ruled out. The Tribunal relied on Supreme Court judgments to strengthen the assessee's case.
The Income Tax Appellate Tribunal allowed the assessee's appeal and directed the Assessing Officer to permit the deduction of bad debts claimed u/s 37(1) of the Income Tax Act. The Tribunal held that the authorities below misunderstood the facts and failed to appreciate the prevailing business scenario. Venturing into diverse sectors is common for large corporate houses. The assessee's investment in the subsidiary was part of its business, and after a long gestation period, the question of it not being part of the assessee's business was ruled out. The Tribunal relied on Supreme Court judgments to strengthen the assessee's case.
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