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 High Court held that a beneficial CBDT circular issued under section 119(2)(b) for condonation of delay in filing prescribed forms must be applied to genuine and bona fide cases, even where the assessment year is not expressly named. The court found that the relevant circular was the one dated 18.11.2024, which addressed condonation of delay, and that omission of AY 2023-24 was not decisive because the circular was meant to remedy genuine hardship. Rejecting a narrow year-specific reading as anomalous and unjust, the court set aside the refusal order and remitted the matter for fresh consideration in accordance with law.
A High Court held that a beneficial CBDT circular issued under section 119(2)(b) for condonation of delay in filing prescribed forms must be applied to genuine and bona fide cases, even where the assessment year is not expressly named. The court found that the relevant circular was the one dated 18.11.2024, which addressed condonation of delay, and that omission of AY 2023-24 was not decisive because the circular was meant to remedy genuine hardship. Rejecting a narrow year-specific reading as anomalous and unjust, the court set aside the refusal order and remitted the matter for fresh consideration in accordance with law.
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