Co-operative society's mandatory reserve and share capital fixed deposits with banks-interest treated as business income under 80P(2)(a)(iii) deductio...
Income tax reassessment reopening after four years on investigation tip, without s.147 proviso disclosure failure, struck down as borrowed satisfactio...
Payments by a trust to related concerns do not automatically attract disallowance under Section 13(1)(c); the statutory test is whether application of income or property results in a direct or indirect benefit to persons specified in Section 13(3), and benefit must be established. Higher profit margins or payments alone are insufficient without comparative or evidential material showing payments were excessive, lacked commercial expediency, or constituted diversion of trust income. Where earlier assessment years with identical facts accepted such payments and there is no change in facts or law, the rule of consistency supports maintaining that view and precludes reopening the transactions under Section 13(1)(c).
Payments by a trust to related concerns do not automatically attract disallowance under Section 13(1)(c); the statutory test is whether application of income or property results in a direct or indirect benefit to persons specified in Section 13(3), and benefit must be established. Higher profit margins or payments alone are insufficient without comparative or evidential material showing payments were excessive, lacked commercial expediency, or constituted diversion of trust income. Where earlier assessment years with identical facts accepted such payments and there is no change in facts or law, the rule of consistency supports maintaining that view and precludes reopening the transactions under Section 13(1)(c).
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4823 
Join Channel 
