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...
Belated claims in CIRP cannot be reopened after CoC approval merely because plan approval by the Adjudicating Authority is pending, and refusal to condone delay was upheld where the claimant was a commercial entity and its claim was not reflected in the corporate debtor's records. The SARFAESI sale certificate preserved liability only for encumbrances expressly listed in Annexure 1, so no enforceable liability survived in favour of a claimant whose name was absent from that list. An allotment of units made in adjustment of legal fees, without any disbursement by the claimant, did not satisfy the requirement of disbursement against consideration for the time value of money and was not financial debt.
Belated claims in CIRP cannot be reopened after CoC approval merely because plan approval by the Adjudicating Authority is pending, and refusal to condone delay was upheld where the claimant was a commercial entity and its claim was not reflected in the corporate debtor's records. The SARFAESI sale certificate preserved liability only for encumbrances expressly listed in Annexure 1, so no enforceable liability survived in favour of a claimant whose name was absent from that list. An allotment of units made in adjustment of legal fees, without any disbursement by the claimant, did not satisfy the requirement of disbursement against consideration for the time value of money and was not financial debt.
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