Transfer pricing requires evidence for AMP transactions, functionally reliable comparables, and appropriate aggregation or Berry Ratio benchmarking me...
Revisionary jurisdiction cannot reopen share capital assessments where adequate inquiry supports a permissible view and no independent error is establ...
Reassessment jurisdiction fails where unverified portal information is aggregated without examining the taxpayer's explanation or relevance of entries...
Statutory sanction for delayed reassessment requires approval from the prescribed authority; approval by an inferior authority invalidates jurisdictio...
Transfer pricing margin adjustments require matching treatment of non-operating income and related costs, with comparability issues reconsidered on ev...
Preliminary-expense amortisation and MAT exempt-income adjustments prevailed, while trademark costs and managerial remuneration require fresh verifica...
Export valuation requires contemporaneous evidence; unrelated invoices cannot prove overvaluation, and dual penalties on firm and partner are impermis...
Section 80P(2)(d) permits a co-operative society to claim deduction on interest or dividend earned from investments with another co-operative society, and a co-operative bank continues to fall within that expression for this purpose. Section 80P(4) withdraws the deduction only in the hands of the co-operative bank itself and does not change its character for section 80P(2)(d). Applying that construction, interest received by a co-operative housing society from deposits with co-operative banks was held deductible. The Tribunal found Totgars Co-operative Sale Society Ltd. inapplicable because it dealt with section 80P(2)(a)(i), and also noted consistent allowance in earlier years on the same facts.
Section 80P(2)(d) permits a co-operative society to claim deduction on interest or dividend earned from investments with another co-operative society, and a co-operative bank continues to fall within that expression for this purpose. Section 80P(4) withdraws the deduction only in the hands of the co-operative bank itself and does not change its character for section 80P(2)(d). Applying that construction, interest received by a co-operative housing society from deposits with co-operative banks was held deductible. The Tribunal found Totgars Co-operative Sale Society Ltd. inapplicable because it dealt with section 80P(2)(a)(i), and also noted consistent allowance in earlier years on the same facts.
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