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...
Reopening beyond three years under section 149(1)(b) requires the escaped income to be represented in the form prescribed by law; mere reference to unrecorded scrap-sale receipts and an estimated profit basis was insufficient, so the reassessment for AYs 2019-20 and 2020-21 was quashed. Ambiguous section 148 notices that inconsistently stated the search basis showed non-application of mind, rendering the notices and reassessments for AYs 2021-22 and 2022-23 invalid. For searches conducted after 1 April 2021, the special post-2021 mechanism under sections 147/148, with prior approval under section 148B, prevails over regular assessment under section 143(3); accordingly, the section 143(3) assessments for AYs 2023-24 and 2024-25 were also quashed.
Reopening beyond three years under section 149(1)(b) requires the escaped income to be represented in the form prescribed by law; mere reference to unrecorded scrap-sale receipts and an estimated profit basis was insufficient, so the reassessment for AYs 2019-20 and 2020-21 was quashed. Ambiguous section 148 notices that inconsistently stated the search basis showed non-application of mind, rendering the notices and reassessments for AYs 2021-22 and 2022-23 invalid. For searches conducted after 1 April 2021, the special post-2021 mechanism under sections 147/148, with prior approval under section 148B, prevails over regular assessment under section 143(3); accordingly, the section 143(3) assessments for AYs 2023-24 and 2024-25 were also quashed.
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