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...
Declared transaction value could not be rejected merely because the discount appeared abnormal, where the importer produced invoices, purchase orders and Cisco communications supporting the higher discount, and the Revenue's comparative material was not examined for comparability. The Tribunal noted there was no allegation of relationship between the importer and supplier or of any payment over and above invoice price. Because the evidentiary record on both sides had not been properly considered, the rejection of value was unsustainable. The order was set aside and the matter remanded for fresh examination of the documents and redetermination of assessable value.
Declared transaction value could not be rejected merely because the discount appeared abnormal, where the importer produced invoices, purchase orders and Cisco communications supporting the higher discount, and the Revenue's comparative material was not examined for comparability. The Tribunal noted there was no allegation of relationship between the importer and supplier or of any payment over and above invoice price. Because the evidentiary record on both sides had not been properly considered, the rejection of value was unsustainable. The order was set aside and the matter remanded for fresh examination of the documents and redetermination of assessable value.
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