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...
A writ challenge to long-pending show cause notices was declined because the petitioners approached the High Court after about eighteen years, showing delay and laches. The Court noted that opportunities and hearing dates had been given after issuance of the notices, but the petitioners did not participate, so the delay in adjudication could not be blamed solely on the department. As factual issues still had to be examined by the competent authority, the Court refused to quash the notices at the writ stage and left all merits open. The petitions were dismissed, with liberty to appear before the authority and raise all available submissions.
A writ challenge to long-pending show cause notices was declined because the petitioners approached the High Court after about eighteen years, showing delay and laches. The Court noted that opportunities and hearing dates had been given after issuance of the notices, but the petitioners did not participate, so the delay in adjudication could not be blamed solely on the department. As factual issues still had to be examined by the competent authority, the Court refused to quash the notices at the writ stage and left all merits open. The petitions were dismissed, with liberty to appear before the authority and raise all available submissions.
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