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...
Section 7 admission requires established financial debt and default, not precise interest quantification, while post-suspension defaults remain action...
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Reassessment notices issued under the new regime were held time-barred because, for notices originally issued between 01/04/2021 and 30/06/2021, only the surviving time available up to 30/06/2021 could be used after excluding the stayed period and the two weeks allowed for response. Applying the Supreme Court rulings in Rajeev Bansal and Ashish Agarwal, the Tribunal held that the fresh notice had to be issued within the remaining limitation under section 149. In this case, the notice issued on 25/07/2022 exceeded that limit, so the reassessment proceedings and assessment orders were quashed, with other grounds left open.
Reassessment notices issued under the new regime were held time-barred because, for notices originally issued between 01/04/2021 and 30/06/2021, only the surviving time available up to 30/06/2021 could be used after excluding the stayed period and the two weeks allowed for response. Applying the Supreme Court rulings in Rajeev Bansal and Ashish Agarwal, the Tribunal held that the fresh notice had to be issued within the remaining limitation under section 149. In this case, the notice issued on 25/07/2022 exceeded that limit, so the reassessment proceedings and assessment orders were quashed, with other grounds left open.
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