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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Validity of penalty proceedings turned on whether the limitation period in clause (c) of Section 275(1) is residuary; the court held clause (c) is residuary and clauses (a) or (b) apply where penalty proceedings originate from an assessment or revision. Because the penalty under the special provision arose from an assessment linked to admissions during search and was appealed, the court applied the limitation computation under clause (a), measuring six months from receipt of the appellate tribunal order and finding the penalty issued on the final permissible date. Revision proceedings were quashed, so clause (b) did not apply, and the writ was dismissed.
Validity of penalty proceedings turned on whether the limitation period in clause (c) of Section 275(1) is residuary; the court held clause (c) is residuary and clauses (a) or (b) apply where penalty proceedings originate from an assessment or revision. Because the penalty under the special provision arose from an assessment linked to admissions during search and was appealed, the court applied the limitation computation under clause (a), measuring six months from receipt of the appellate tribunal order and finding the penalty issued on the final permissible date. Revision proceedings were quashed, so clause (b) did not apply, and the writ was dismissed.
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