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 scrutiny assessment was held invalid because the section 143(2) notice was issued by an officer lacking pecuniary jurisdiction under CBDT Instruction No. 1/2011. The return disclosed a loss above the limit assigned to the Income Tax Officer for metro charges, so jurisdiction vested in the Deputy Commissioner and not the ITO who issued the notice. The Tribunal treated the section 143(2) notice requirement as mandatory, not a curable procedural defect, and quashed the resulting assessment.
A scrutiny assessment was held invalid because the section 143(2) notice was issued by an officer lacking pecuniary jurisdiction under CBDT Instruction No. 1/2011. The return disclosed a loss above the limit assigned to the Income Tax Officer for metro charges, so jurisdiction vested in the Deputy Commissioner and not the ITO who issued the notice. The Tribunal treated the section 143(2) notice requirement as mandatory, not a curable procedural defect, and quashed the resulting assessment.
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