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...
Foreign remittance compliance turned on whether the appellant could prove import through valid Bills of Entry linked to the impugned remittances and asserted high sea sale documents. The Tribunal found that the Bill of Entry related to the same Bill of Lading, but the handwritten notation relied on to show coverage of all three remittances was partly illegible and not shown to have been made by authorised personnel. Customs records did not establish duty on the full amount claimed, and RBI confirmed that the relevant Bills of Entry had not been submitted to the Authorised Dealer. Contravention was therefore sustained, but the penalty was reduced and the pre-deposit adjusted.
Foreign remittance compliance turned on whether the appellant could prove import through valid Bills of Entry linked to the impugned remittances and asserted high sea sale documents. The Tribunal found that the Bill of Entry related to the same Bill of Lading, but the handwritten notation relied on to show coverage of all three remittances was partly illegible and not shown to have been made by authorised personnel. Customs records did not establish duty on the full amount claimed, and RBI confirmed that the relevant Bills of Entry had not been submitted to the Authorised Dealer. Contravention was therefore sustained, but the penalty was reduced and the pre-deposit adjusted.
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