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...
Exemption under section 54B requires proof of actual agricultural use of the land during the prescribed period; mere classification in revenue records is insufficient. The Tribunal found that revised 7/12 extracts could only raise a presumption and were not conclusive without corroborative evidence such as produce sale bills, seed or fertiliser purchase records, labour records, or other material showing active cultivation. As no such evidence was produced, the essential statutory condition remained unproved and the denial of exemption was upheld, with the addition sustained. The Tribunal also distinguished the cited contrary precedent on facts and relied on authority holding that revenue entries alone do not establish agricultural use.
Exemption under section 54B requires proof of actual agricultural use of the land during the prescribed period; mere classification in revenue records is insufficient. The Tribunal found that revised 7/12 extracts could only raise a presumption and were not conclusive without corroborative evidence such as produce sale bills, seed or fertiliser purchase records, labour records, or other material showing active cultivation. As no such evidence was produced, the essential statutory condition remained unproved and the denial of exemption was upheld, with the addition sustained. The Tribunal also distinguished the cited contrary precedent on facts and relied on authority holding that revenue entries alone do not establish agricultural use.
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