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 251(1) enhancement power was confined to matters or sources of income considered by the Assessing Officer; the CIT(A) could not introduce a fresh issue by reducing work-in-progress on a point never examined in assessment, so the enhancement was invalid and reversed. Receipts under the joint development arrangement were treated as security deposits and business receipts, not loans or advances, and deemed dividend under section 2(22)(e) could be taxed only in the hands of a shareholder; as the assessee was neither a registered nor beneficial shareholder, the addition was deleted. For the joint development agreement, the asset was stock-in-trade and income had to be measured by the consideration actually receivable under the arrangement, not by stamp duty value of the entire land parcel, so the protective addition for alleged extra consideration was affirmed as deleted.
Section 251(1) enhancement power was confined to matters or sources of income considered by the Assessing Officer; the CIT(A) could not introduce a fresh issue by reducing work-in-progress on a point never examined in assessment, so the enhancement was invalid and reversed. Receipts under the joint development arrangement were treated as security deposits and business receipts, not loans or advances, and deemed dividend under section 2(22)(e) could be taxed only in the hands of a shareholder; as the assessee was neither a registered nor beneficial shareholder, the addition was deleted. For the joint development agreement, the asset was stock-in-trade and income had to be measured by the consideration actually receivable under the arrangement, not by stamp duty value of the entire land parcel, so the protective addition for alleged extra consideration was affirmed as deleted.
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