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...
Treatment of interest deduction under Income from Other Sources: an inadmissible claim of interest deduction that neutralises disclosed interest income and is not substantiated attracts penalty under the penalty regime for under reporting of income. Principle of consistency was held inapplicable where earlier returns were processed under summary intimation and no scrutiny assessment was carried out, because such intimation does not preclude re examination. Immunity clauses for bona fide explanations or estimation do not apply where the assessee fails to disclose all material facts, specifically the nexus between funds borrowed and loans given; on that factual failure the assessing officer's disallowance and consequent penalty were sustained.
Treatment of interest deduction under Income from Other Sources: an inadmissible claim of interest deduction that neutralises disclosed interest income and is not substantiated attracts penalty under the penalty regime for under reporting of income. Principle of consistency was held inapplicable where earlier returns were processed under summary intimation and no scrutiny assessment was carried out, because such intimation does not preclude re examination. Immunity clauses for bona fide explanations or estimation do not apply where the assessee fails to disclose all material facts, specifically the nexus between funds borrowed and loans given; on that factual failure the assessing officer's disallowance and consequent penalty were sustained.
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