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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...
Official certificates and revenue records admitted by the first appellate authority were treated as properly relied upon because they went to the root of the dispute and no specific prejudice to the Revenue was shown. On the merits, the land was accepted as rural agricultural land on the basis of urban development authority certificates, revenue records and census data showing it lay beyond the prescribed municipal distance. As the Assessing Officer produced no independent verification or conclusive contrary evidence, the lands were held to fall outside section 2(14) and outside section 194-IA, so the assessee could not be treated as an assessee in default under section 201(1) and interest under section 201(1A) was not sustainable.
Official certificates and revenue records admitted by the first appellate authority were treated as properly relied upon because they went to the root of the dispute and no specific prejudice to the Revenue was shown. On the merits, the land was accepted as rural agricultural land on the basis of urban development authority certificates, revenue records and census data showing it lay beyond the prescribed municipal distance. As the Assessing Officer produced no independent verification or conclusive contrary evidence, the lands were held to fall outside section 2(14) and outside section 194-IA, so the assessee could not be treated as an assessee in default under section 201(1) and interest under section 201(1A) was not sustainable.
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