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...
HC quashed reassessment under Section 148 where the only basis was an entry in a broker's seized inquiry register. The Court held that seized material must have a live nexus with the assessee and must pertain to or relate to the assessee; here, the entry pre-dated the purchase by nearly twenty-three months, referred to lands available for sale, covered multiple survey numbers and a larger area, and named another person. On these facts, the register entry could not support a presumption of escapement of income, and the reopening was based on conjectures and surmises. The notice for the assessment year 2021-22 was quashed.
HC quashed reassessment under Section 148 where the only basis was an entry in a broker's seized inquiry register. The Court held that seized material must have a live nexus with the assessee and must pertain to or relate to the assessee; here, the entry pre-dated the purchase by nearly twenty-three months, referred to lands available for sale, covered multiple survey numbers and a larger area, and named another person. On these facts, the register entry could not support a presumption of escapement of income, and the reopening was based on conjectures and surmises. The notice for the assessment year 2021-22 was quashed.
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