Trademark depreciation and section 14A adjustments: ITAT applies consistency, independent book-profit computation, and no disallowance without exempt ...
Rebuttable search presumptions and corroboration standards shaped deletion of unsubstantiated additions, while rental income and limited profit estima...
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A co-operative bank's TDS position on interest paid to co-operative society depositors was traced to the CBDT Explanatory Note, not the proviso inserted in section 194A(3); the Court treated the Note as binding on the Department and held that the proviso only curtailed the broader exemption available to other co-operative societies. The proviso's constitutional challenge failed because exemption from TDS is a matter of legislative policy and section 80P is only a deduction provision, not a full tax exemption. The challenge based on administrative burden also failed, and protection was sustained for non-deduction done in obedience to subsisting interim orders.
A co-operative bank's TDS position on interest paid to co-operative society depositors was traced to the CBDT Explanatory Note, not the proviso inserted in section 194A(3); the Court treated the Note as binding on the Department and held that the proviso only curtailed the broader exemption available to other co-operative societies. The proviso's constitutional challenge failed because exemption from TDS is a matter of legislative policy and section 80P is only a deduction provision, not a full tax exemption. The challenge based on administrative burden also failed, and protection was sustained for non-deduction done in obedience to subsisting interim orders.
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