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...
Under the mercantile system, a continuing obligation to provide promised facilities and amenities over a long-term timeshare membership period gave rise to an accrued, estimable liability, so proportionate revenue recognition was permissible. The Court held that the concept of deferred income is not alien to the Income-tax Act and applied the matching principle to the assessee's advance membership collections. Annual maintenance or utility charges collected separately were not equivalent to the contractual facilities promised under the membership arrangement. The Tribunal erred in taxing the entire membership receipt in the first year, and the substantial questions of law were answered in favour of the assessee.
Under the mercantile system, a continuing obligation to provide promised facilities and amenities over a long-term timeshare membership period gave rise to an accrued, estimable liability, so proportionate revenue recognition was permissible. The Court held that the concept of deferred income is not alien to the Income-tax Act and applied the matching principle to the assessee's advance membership collections. Annual maintenance or utility charges collected separately were not equivalent to the contractual facilities promised under the membership arrangement. The Tribunal erred in taxing the entire membership receipt in the first year, and the substantial questions of law were answered in favour of the assessee.
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