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...
Ad hoc gross profit estimation was held inappropriate where the Revenue sought to reject books of account after a survey and treat surrendered excess stock as a basis for additional income. The Tribunal noted that gross profit rates may vary between pre-survey and post-survey periods because market prices fluctuate, and that excess stock found in survey must be brought into the books and reflected in closing stock at the lower of cost or market price under AS-2. On that reasoning, the books could not be rejected on the stated grounds and the addition founded on ad hoc gross profit estimation was not sustainable.
Ad hoc gross profit estimation was held inappropriate where the Revenue sought to reject books of account after a survey and treat surrendered excess stock as a basis for additional income. The Tribunal noted that gross profit rates may vary between pre-survey and post-survey periods because market prices fluctuate, and that excess stock found in survey must be brought into the books and reflected in closing stock at the lower of cost or market price under AS-2. On that reasoning, the books could not be rejected on the stated grounds and the addition founded on ad hoc gross profit estimation was not sustainable.
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