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...
Reopening of assessment under the new regime requires supplying to the taxpayer the materials forming the basis for reopening; where only a notice and reasons recorded were provided without annexed material, the taxpayer was deprived of an effective opportunity to respond and the subsequent order under the new procedure was invalidated. The note emphasises that failure to furnish underlying information precludes meaningful representation and renders the reopening notice defective, aligning with higher-court guidance that materials must be disclosed before final action is taken.
Reopening of assessment under the new regime requires supplying to the taxpayer the materials forming the basis for reopening; where only a notice and reasons recorded were provided without annexed material, the taxpayer was deprived of an effective opportunity to respond and the subsequent order under the new procedure was invalidated. The note emphasises that failure to furnish underlying information precludes meaningful representation and renders the reopening notice defective, aligning with higher-court guidance that materials must be disclosed before final action is taken.
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