Donor-directed corpus contributions retain capital character despite exemption claims under section 10(23C)(vi), preventing their treatment as taxable...
Enhanced tax-audit threshold applies where banking records establish compliant non-cash receipts and payments, eliminating penalty exposure for audit ...
Transfer pricing consistency protects identical non-interest-bearing debenture terms from a later notional-interest adjustment without valid statutory...
Rectification of debatable deduction claims cannot reverse scrutiny-approved co-operative society interest income deductions as apparent record errors...
Cash-method accounting bars presumptive interest taxation, while unsupported securities and share-trading additions require reliable material and veri...
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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