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...
Quantification of weighted deduction under section 35(2AB) depended on the expenditure approved in Form 3CL, not on the assessee's basic eligibility for the deduction. The Tribunal held that Form 3CL had already been sent to the jurisdictional Assessing Officer and therefore could not be rejected as additional evidence in rectification proceedings. Reading Rule 6(7A) for the relevant assessment year, the Assessing Officer was required to take cognizance of the approved expenditure and recompute the deduction accordingly. The impugned order was set aside and the issue was restored for fresh quantification after giving the assessee a reasonable opportunity of hearing.
Quantification of weighted deduction under section 35(2AB) depended on the expenditure approved in Form 3CL, not on the assessee's basic eligibility for the deduction. The Tribunal held that Form 3CL had already been sent to the jurisdictional Assessing Officer and therefore could not be rejected as additional evidence in rectification proceedings. Reading Rule 6(7A) for the relevant assessment year, the Assessing Officer was required to take cognizance of the approved expenditure and recompute the deduction accordingly. The impugned order was set aside and the issue was restored for fresh quantification after giving the assessee a reasonable opportunity of hearing.
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