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 borrower account fraud classification was quashed where the bank relied on a transaction audit report already found insufficient to support undervaluation, preferential or fraudulent transactions, and also on undisclosed Joint Lenders Meeting material. Because those materials were not supplied in the show cause notice or otherwise disclosed, the petitioners had no effective opportunity to respond, and the bank could not cure the defect by later referring to an FIR that had not formed part of the original decision-making record. The Court held that the process violated audi alteram partem and that the impugned order was non-speaking, while reserving liberty to proceed afresh in accordance with law and RBI directions.
A borrower account fraud classification was quashed where the bank relied on a transaction audit report already found insufficient to support undervaluation, preferential or fraudulent transactions, and also on undisclosed Joint Lenders Meeting material. Because those materials were not supplied in the show cause notice or otherwise disclosed, the petitioners had no effective opportunity to respond, and the bank could not cure the defect by later referring to an FIR that had not formed part of the original decision-making record. The Court held that the process violated audi alteram partem and that the impugned order was non-speaking, while reserving liberty to proceed afresh in accordance with law and RBI directions.
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