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...
Section 7 admission requires established financial debt and default, not precise interest quantification, while post-suspension defaults remain action...
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For search-related reassessment, the HC held that the six-year block under section 153A and the extended ten-year block under Explanation 1 use different computation methods, and the language of the ten-year provision requires the search assessment year to be included as the first year in the reckoning. On that construction, a search conducted in FY 2023-24 made AY 2024-25 the first year and AY 2015-16 the tenth year, so AY 2014-15 fell outside the permissible period. The Court followed its earlier view and rejected the Revenue's contrary interpretation, quashing the section 148 notice for AY 2014-15 as time-barred.
For search-related reassessment, the HC held that the six-year block under section 153A and the extended ten-year block under Explanation 1 use different computation methods, and the language of the ten-year provision requires the search assessment year to be included as the first year in the reckoning. On that construction, a search conducted in FY 2023-24 made AY 2024-25 the first year and AY 2015-16 the tenth year, so AY 2014-15 fell outside the permissible period. The Court followed its earlier view and rejected the Revenue's contrary interpretation, quashing the section 148 notice for AY 2014-15 as time-barred.
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