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 7 admission requires established financial debt and default, not precise interest quantification, while post-suspension defaults remain action...
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Trade receivables under TNMM were treated as integral to the international transactions, so a separate notional interest adjustment was deleted where working capital adjustment had already captured the receivables impact and no distinct financing arrangement was shown. Goodwill arising on amalgamation was accepted as a depreciable acquired intangible, and depreciation was allowed. Product registration and regulatory approval were held to be revenue in nature because they facilitated existing business operations rather than creating a capital asset. For section 80-IC, the Tribunal upheld full deduction on manufacturing profits without hypothetical brand-royalty allocation, included scrap income as derived from manufacturing, and confirmed 100% deduction after substantial expansion in line with Aarham Softronics.
Trade receivables under TNMM were treated as integral to the international transactions, so a separate notional interest adjustment was deleted where working capital adjustment had already captured the receivables impact and no distinct financing arrangement was shown. Goodwill arising on amalgamation was accepted as a depreciable acquired intangible, and depreciation was allowed. Product registration and regulatory approval were held to be revenue in nature because they facilitated existing business operations rather than creating a capital asset. For section 80-IC, the Tribunal upheld full deduction on manufacturing profits without hypothetical brand-royalty allocation, included scrap income as derived from manufacturing, and confirmed 100% deduction after substantial expansion in line with Aarham Softronics.
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