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...
The Tribunal addressed double disallowance of a subsidiary investment write-off by noting that the amount had already been added back in the return, so the Assessing Officer had duplicated the disallowance; the duplicate addition was to be deleted and the allowed deduction then given effect. It also accepted that fresh claims may be entertained on appeal and excluded broken period interest on debentures because the income had only accrued notionally and was already absorbed in the later capital gains on sale, avoiding double taxation. A dividend treaty-rate claim for non-resident shareholders was remanded for lack of foundational treaty-eligibility and tax-treatment material, and the challenge to initiation of penalty proceedings was dismissed as premature.
The Tribunal addressed double disallowance of a subsidiary investment write-off by noting that the amount had already been added back in the return, so the Assessing Officer had duplicated the disallowance; the duplicate addition was to be deleted and the allowed deduction then given effect. It also accepted that fresh claims may be entertained on appeal and excluded broken period interest on debentures because the income had only accrued notionally and was already absorbed in the later capital gains on sale, avoiding double taxation. A dividend treaty-rate claim for non-resident shareholders was remanded for lack of foundational treaty-eligibility and tax-treatment material, and the challenge to initiation of penalty proceedings was dismissed as premature.
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