Human-probability test defeats political donation deductions where banking records mask accommodation-entry fund layering rather than genuine contribu...
Electronic evidence and search statements in tax assessments require authenticity review and corroboration, while procedural manuals lack statutory fo...
Tariff rate quota authorisations govern preferential imports of specified New Zealand goods through export certification and electronic customs debiti...
Electronic Continuity Bond Registration replaces manual container permissions, with quarterly reporting and re-export monitoring for duty-free contain...
Whether interest on enhanced compensation is taxable or exempt: Holding that plain language of s.56(2)(viii) read with s.145B(1) brings interest on enhanced compensation under "income from other sources," and s.10(37) covers only compensation (not interest); outcome-interest is exigible to tax and exemption claim fails. Whether revision u/s 263 was justified: PCIT found AO failed to make requisite statutory and judicial inquiries (including jurisdictional HC precedents), rendering the assessment erroneous and prejudicial; outcome-revision u/s 263 was valid and recomputation under s.56(2)(viii) r.w.s.145B(1) with s.57(iv) deduction affirmed. - ITAT
Whether interest on enhanced compensation is taxable or exempt: Holding that plain language of s.56(2)(viii) read with s.145B(1) brings interest on enhanced compensation under "income from other sources," and s.10(37) covers only compensation (not interest); outcome-interest is exigible to tax and exemption claim fails. Whether revision u/s 263 was justified: PCIT found AO failed to make requisite statutory and judicial inquiries (including jurisdictional HC precedents), rendering the assessment erroneous and prejudicial; outcome-revision u/s 263 was valid and recomputation under s.56(2)(viii) r.w.s.145B(1) with s.57(iv) deduction affirmed. - ITAT
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