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...
Conflicting coordinate Bench decisions on whether bank commitment charges for keeping sanctioned loan funds available are exigible to service tax required a Larger Bench reference. One view treated the charges as consideration for the bank's contractual commitment to lend, with a clear quid pro quo and no character as interest; the other view, invoking judicial discipline, found that earlier coordinate decisions could not be ignored and that the matter should be placed before the President for constitution of a Larger Bench. The substantive taxability question, along with the precedential effect of the appellant's earlier case, was left open for authoritative determination.
Conflicting coordinate Bench decisions on whether bank commitment charges for keeping sanctioned loan funds available are exigible to service tax required a Larger Bench reference. One view treated the charges as consideration for the bank's contractual commitment to lend, with a clear quid pro quo and no character as interest; the other view, invoking judicial discipline, found that earlier coordinate decisions could not be ignored and that the matter should be placed before the President for constitution of a Larger Bench. The substantive taxability question, along with the precedential effect of the appellant's earlier case, was left open for authoritative determination.
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