Transfer pricing comparability requires functional alignment and permits working capital adjustment, while APA margins cannot govern non-covered years...
Treaty benefit, goodwill depreciation and hedging costs: export commission disallowed, while key business deductions and depreciation claims succeeded...
Undisclosed foreign asset classification requires an unexplained source; unrebutted affidavits and corroborative evidence defeated the Black Money Act...
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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