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...
Transfer pricing adjustment on AMP expenditure was deleted because the Bright Line Test could not be applied to determine arm's length price, following Delhi High Court and coordinate Bench precedent; the Tribunal held no adjustment was warranted on the assessee's AMP spend. The section 43B issue on bonus payment was not decided on merits and was remitted to verify whether the bonus was paid within the return-filing due date, in which case no addition would arise. Claims relating to short grant of self-assessment tax credit and deduction of interest on VAT duty were also restored for fresh examination. The appeal was thus partly allowed.
Transfer pricing adjustment on AMP expenditure was deleted because the Bright Line Test could not be applied to determine arm's length price, following Delhi High Court and coordinate Bench precedent; the Tribunal held no adjustment was warranted on the assessee's AMP spend. The section 43B issue on bonus payment was not decided on merits and was remitted to verify whether the bonus was paid within the return-filing due date, in which case no addition would arise. Claims relating to short grant of self-assessment tax credit and deduction of interest on VAT duty were also restored for fresh examination. The appeal was thus partly allowed.
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