Extended reassessment limitation in search cases requires asset-linked escaped income, invalidating additions based only on unexplained money or expen...
Enhanced tolerance band under section 43CA applies retrospectively, deleting qualifying deemed-sale additions while disputed stamp valuation requires ...
Customs transaction value rejection requires communicated reasonable doubt, while written reassessment acceptance preserves challenges to enhanced val...
Challenge-mechanism compliance clarifications permitted, while unilateral revised resolution plans may be refused under creditors' commercial discreti...
Revisionary jurisdiction applies where a reassessment accepts non-taxability of accumulated interest without necessary inquiry or application of governing provisions, rendering it erroneous and prejudicial to Revenue interests and permitting fresh determination. Premature conversion of zero-coupon debentures into equity shares of ascertainable value can constitute constructive receipt of accumulated interest even under cash-basis accounting. Claiming tax-deducted-at-source credit for that interest is inconsistent with denying the underlying income. The capital-gains exclusion for conversion does not exempt embedded interest from taxation; once taxed, the interest forms part of the shares' cost basis, preventing double taxation on sale.
Revisionary jurisdiction applies where a reassessment accepts non-taxability of accumulated interest without necessary inquiry or application of governing provisions, rendering it erroneous and prejudicial to Revenue interests and permitting fresh determination. Premature conversion of zero-coupon debentures into equity shares of ascertainable value can constitute constructive receipt of accumulated interest even under cash-basis accounting. Claiming tax-deducted-at-source credit for that interest is inconsistent with denying the underlying income. The capital-gains exclusion for conversion does not exempt embedded interest from taxation; once taxed, the interest forms part of the shares' cost basis, preventing double taxation on sale.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4912 
