Pre-amendment reassessment limitation bars late notices under the preserved regime, invalidating consequential reassessment for affected earlier asses...
Cash-sales explanations for bank deposits require documentary reconciliation; reassessment notice survived where effective response time was available...
Functional comparability in transfer pricing prevents ad hoc arm's length adjustments where functions, assets, risks and reliable comparables are unes...
Contingency expenses, exempt-income disallowance, and royalty benchmarking: unsupported adjustments were deleted under consistent accounting and trans...
A co-operative credit society carrying on borrowing and lending only with members was entitled to deduction under section 80P(2)(a)(i) because no dealings with non-members were shown, and section 80P remains a benevolent provision available to societies providing credit facilities to members. The interest income was also held to be profits attributable to that credit business and therefore deductible under section 80P(2)(a)(i). Authorities dealing with section 80P(2)(d) were held inapplicable because they concerned a different statutory question. The Revenue's challenge was rejected.
A co-operative credit society carrying on borrowing and lending only with members was entitled to deduction under section 80P(2)(a)(i) because no dealings with non-members were shown, and section 80P remains a benevolent provision available to societies providing credit facilities to members. The interest income was also held to be profits attributable to that credit business and therefore deductible under section 80P(2)(a)(i). Authorities dealing with section 80P(2)(d) were held inapplicable because they concerned a different statutory question. The Revenue's challenge was rejected.
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