Transfer pricing comparability requires functional alignment, reliable financial data, and careful review of working capital and receivables adjustmen...
Transfer pricing rules require benchmarking corporate guarantees and associated-enterprise advances, while invalid domestic-transaction adjustments ca...
Prospective sugar export prohibition required registered letters of credit; private contracts and export quotas created no enforceable continuation ri...
Retroactive interim-moratorium exclusion permits protective asset disclosure and preservation measures against personal guarantors pending arbitration...
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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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