Commercial expediency supports interest deductions where interest-free advances fund a wholly owned subsidiary's genuine group business project.
Marketing expenditure substantiation may justify limited disallowance, but does not alone establish income misreporting for penalty purposes.
Dealing-error and squared-off derivative losses qualify as allowable business losses when supported by contemporaneous transaction records.
Specified income exemption for the real estate regulatory authority depends on non-commercial activity, return filing, and unchanged income sources.
Specified regulatory authority income receives conditional tax exemption, subject to non-commercial activity, unchanged income character, and return f...
Tax exemption for regulatory authority income applies retrospectively, subject to non-commercial activity, unchanged income sources, and return-filing...
Misreporting penalty notices must state their factual basis; unsupported allegations cannot sustain enhanced tax penalties.
Live nexus with the assessee is essential before seized broker records can support reassessment for alleged unrecorded consideration.
Genuine hardship in belated Form 10 filings requires justice-oriented consideration, enabling accumulation exemption claims where prescribed investmen...
Bogus donation receipts justified commission income assessment and defeated political-party tax exemption for inaccurate accounts and reporting failur...
Statutory deferral of final assessment protects Dispute Resolution Panel objections until directions are issued and proceedings lawfully resume.
Reassessment limits and operating subsidy treatment govern transfer-pricing benchmarking of closely linked distribution transactions.
Pure reimbursement without income element escapes tax withholding, while delayed withholding and unsupported provisions face deferred or renewed scrut...
Public benefit requirement defeats charitable registration where residents' association services are reciprocal, member-only facilities governed by mu...
Limited look-back confines charitable registration renewal scrutiny and bars reliance on historical allegations during Form 10AB assessment.
Foreign exchange loss on capital borrowing remains capital in nature and cannot be claimed as business expenditure.
Make-available test excludes dependent research support fees from FTS treatment, leaving them taxable only as business profits.
Scope of registration enquiry requires evidence-based scrutiny, while existing charitable registration needs separate statutory cancellation procedure...
Continuing new tax regime option remains effective despite an incorrect first-year declaration in a later return.
Exempt-income expenditure disallowance is confined to investments that actually generated exempt income, while supported business expenses remain dedu...
TaxTMI 
TaxTMI 
of 1979 
