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...
FEMA applied to unrealised export proceeds where the extended repatriation period expired while FEMA was in force; earlier FERA proceedings did not bar action on different export bills, and mere local-currency deposit abroad was not sufficient evidence of taking all reasonable steps to realise the dues. The Tribunal therefore sustained the finding of contravention. For vicarious liability, it held that Section 42 does not depend only on formal designation: a partner or person who signed bank extension letters and participated in export realisation and firm management could be held personally liable where no preventive steps were shown. Penalty on both appellants was upheld.
FEMA applied to unrealised export proceeds where the extended repatriation period expired while FEMA was in force; earlier FERA proceedings did not bar action on different export bills, and mere local-currency deposit abroad was not sufficient evidence of taking all reasonable steps to realise the dues. The Tribunal therefore sustained the finding of contravention. For vicarious liability, it held that Section 42 does not depend only on formal designation: a partner or person who signed bank extension letters and participated in export realisation and firm management could be held personally liable where no preventive steps were shown. Penalty on both appellants was upheld.
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