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...
CBDT Instruction No. 1916, though framed for non-seizure of jewellery during search, was treated as a relevant guideline recognising customary family holdings of jewellery. The Tribunal accepted that jewellery within the prescribed limits could not be regarded as unexplained investment merely because it was found during search, especially where the assessee furnished explanations supported by family holdings, a wealth-tax disclosure for the HUF, purchase bills, and statements recorded during search and assessment. On that basis, the addition under unexplained investment was directed to be deleted to the extent covered by the instruction.
CBDT Instruction No. 1916, though framed for non-seizure of jewellery during search, was treated as a relevant guideline recognising customary family holdings of jewellery. The Tribunal accepted that jewellery within the prescribed limits could not be regarded as unexplained investment merely because it was found during search, especially where the assessee furnished explanations supported by family holdings, a wealth-tax disclosure for the HUF, purchase bills, and statements recorded during search and assessment. On that basis, the addition under unexplained investment was directed to be deleted to the extent covered by the instruction.
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