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...
Remittances to Indian NRE accounts were held explained where the assessee produced tax residency certificates, foreign tax returns, bank statements and Indian account records showing long-standing foreign income and accumulated savings. The Tribunal found that the funds were transferred through banking channels with a direct nexus to the foreign bank account, so the explanation could not be rejected merely for non-compliance at assessment stage or for comparing remittances with the wrong income period. Because the remittances were satisfactorily explained, the linked investment in immovable property was also not treated as unexplained. The additions under section 69 were deleted.
Remittances to Indian NRE accounts were held explained where the assessee produced tax residency certificates, foreign tax returns, bank statements and Indian account records showing long-standing foreign income and accumulated savings. The Tribunal found that the funds were transferred through banking channels with a direct nexus to the foreign bank account, so the explanation could not be rejected merely for non-compliance at assessment stage or for comparing remittances with the wrong income period. Because the remittances were satisfactorily explained, the linked investment in immovable property was also not treated as unexplained. The additions under section 69 were deleted.
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