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...
Unreliable salary records justified rejection of the books of account where discrepancies in wage and salary registers remained unexplained, including mismatches with profit and loss account entries, inconsistent signatures, missing names and addresses, and unsupported cash payments. Once the books were rejected, profit had to be estimated on a rational basis; an 8 per cent net profit rate was held arbitrary because no justification was shown. The assessee's past net profit history of about 1 to 2 per cent was treated as the proper guide, and net profit was directed to be computed at 3 per cent of turnover.
Unreliable salary records justified rejection of the books of account where discrepancies in wage and salary registers remained unexplained, including mismatches with profit and loss account entries, inconsistent signatures, missing names and addresses, and unsupported cash payments. Once the books were rejected, profit had to be estimated on a rational basis; an 8 per cent net profit rate was held arbitrary because no justification was shown. The assessee's past net profit history of about 1 to 2 per cent was treated as the proper guide, and net profit was directed to be computed at 3 per cent of turnover.
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