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 Government company wholly controlled by the State Government through the Governor, with power to appoint and remove directors, was treated as eligible for exemption under section 10(26B) on the basis of its incorporation documents and memorandum and articles of association. The Tribunal followed the co-ordinate bench view in the assessee's own case and accepted that the company was established by the State, so its income was exempt. As the Revenue did not dispute the foundational facts and only raised res judicata, the Tribunal found no error in deleting the additions as non-taxable and upheld the exemption.
A Government company wholly controlled by the State Government through the Governor, with power to appoint and remove directors, was treated as eligible for exemption under section 10(26B) on the basis of its incorporation documents and memorandum and articles of association. The Tribunal followed the co-ordinate bench view in the assessee's own case and accepted that the company was established by the State, so its income was exempt. As the Revenue did not dispute the foundational facts and only raised res judicata, the Tribunal found no error in deleting the additions as non-taxable and upheld the exemption.
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