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 68 was largely satisfied where the assessee produced the lender's registration, PAN, bank statements, debenture documents, confirmation and source-of-source material; nil income alone did not negate creditworthiness, so only limited third-party verification under section 133(6) was left open if the Assessing Officer still needed the lender's accounts. Interest disallowance under section 40A(2)(b) failed because the lender was only a creditor, not shown to be a covered related concern, and no basis existed for adopting 6% as a reasonable rate. Proportionate interest disallowance under section 36(1)(iii) was deleted since the borrowing was for working capital, not capital asset acquisition. A flat 10% ad hoc expense disallowance was set aside for fresh verification. CSR disallowance was upheld, and TDS credit was directed to be verified.
Section 68 was largely satisfied where the assessee produced the lender's registration, PAN, bank statements, debenture documents, confirmation and source-of-source material; nil income alone did not negate creditworthiness, so only limited third-party verification under section 133(6) was left open if the Assessing Officer still needed the lender's accounts. Interest disallowance under section 40A(2)(b) failed because the lender was only a creditor, not shown to be a covered related concern, and no basis existed for adopting 6% as a reasonable rate. Proportionate interest disallowance under section 36(1)(iii) was deleted since the borrowing was for working capital, not capital asset acquisition. A flat 10% ad hoc expense disallowance was set aside for fresh verification. CSR disallowance was upheld, and TDS credit was directed to be verified.
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