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...
A technical defect in the CBDT-prescribed format of notice under section 143(2) was held insufficient, by itself, to invalidate the assessment, as the format instruction was not binding on the Tribunal. On merits, cash receipts arising from accepted sales and recorded trade debtors could not be treated as unexplained money under section 69A where the books, sale bills and purchase records showed genuine business transactions; an addition based only on the cash-sales-to-cash-deposit ratio during demonetisation was rejected, and double taxation of the same business receipts was impermissible. The Tribunal also held that section 68 could not be invoked for credits representing realisation of existing trade debtors, not fresh loans or advances, so that addition was deleted.
A technical defect in the CBDT-prescribed format of notice under section 143(2) was held insufficient, by itself, to invalidate the assessment, as the format instruction was not binding on the Tribunal. On merits, cash receipts arising from accepted sales and recorded trade debtors could not be treated as unexplained money under section 69A where the books, sale bills and purchase records showed genuine business transactions; an addition based only on the cash-sales-to-cash-deposit ratio during demonetisation was rejected, and double taxation of the same business receipts was impermissible. The Tribunal also held that section 68 could not be invoked for credits representing realisation of existing trade debtors, not fresh loans or advances, so that addition was deleted.
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