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 receipt under a collaboration agreement was treated as a business transaction, not an unexplained cash credit, because it moved through account-to-account banking channels and the payer's bank account showed no cash deposit before transfer. The assessee produced corporate records, PAN, returns, accounts and bank statements establishing identity, creditworthiness and genuineness; once that material was filed, the burden shifted to the department, which was not discharged. The Tribunal found the accommodation entry allegation unsupported by enquiry and based on suspicion, and deleted the section 68 addition. The reassessment ground was left open and not decided.
A receipt under a collaboration agreement was treated as a business transaction, not an unexplained cash credit, because it moved through account-to-account banking channels and the payer's bank account showed no cash deposit before transfer. The assessee produced corporate records, PAN, returns, accounts and bank statements establishing identity, creditworthiness and genuineness; once that material was filed, the burden shifted to the department, which was not discharged. The Tribunal found the accommodation entry allegation unsupported by enquiry and based on suspicion, and deleted the section 68 addition. The reassessment ground was left open and not decided.
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