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 7 admission requires established financial debt and default, not precise interest quantification, while post-suspension defaults remain action...
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Tax deducted from sale proceeds of immovable property sold by a bank under SARFAESI was held referable to Section 194IA. The High Court reasoned that, in such an auction, the bank is not the owner of the secured asset but only holds possession and a security interest for recovery of dues, acting as a trustee or custodian of the sale proceeds and applying them towards dues, expenses and any surplus to the borrower. Because the property was not the bank's own asset, credit or refund of the tax deducted could not be denied merely because the bank had not offered corresponding income from sale. The orders granting TDS credit were affirmed and the appeal was dismissed.
Tax deducted from sale proceeds of immovable property sold by a bank under SARFAESI was held referable to Section 194IA. The High Court reasoned that, in such an auction, the bank is not the owner of the secured asset but only holds possession and a security interest for recovery of dues, acting as a trustee or custodian of the sale proceeds and applying them towards dues, expenses and any surplus to the borrower. Because the property was not the bank's own asset, credit or refund of the tax deducted could not be denied merely because the bank had not offered corresponding income from sale. The orders granting TDS credit were affirmed and the appeal was dismissed.
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