Transfer pricing comparables and adjustments: Tribunal revisits loss-maker status, segmental comparability, working capital relief, and risk allocatio...
Business expenditure disallowance failed where commission, related-party salary and promotion payments were supported by records and inquiry was inade...
Interest earned by a co-operative credit society on temporarily parked business funds in bank deposits was treated as income attributable to its business of providing credit facilities to members, making it eligible for deduction under section 80P(2)(a)(i). The Tribunal followed binding jurisdictional precedent, relied on Tumkur Merchants and later similar decisions, and distinguished Totgars because that ruling concerned retained sale proceeds payable to members, not business funds of a society exclusively engaged in credit activity. It also applied judicial discipline by following the Karnataka High Court over contrary views. On identical facts, the same deduction was extended to the other assessment years.
Interest earned by a co-operative credit society on temporarily parked business funds in bank deposits was treated as income attributable to its business of providing credit facilities to members, making it eligible for deduction under section 80P(2)(a)(i). The Tribunal followed binding jurisdictional precedent, relied on Tumkur Merchants and later similar decisions, and distinguished Totgars because that ruling concerned retained sale proceeds payable to members, not business funds of a society exclusively engaged in credit activity. It also applied judicial discipline by following the Karnataka High Court over contrary views. On identical facts, the same deduction was extended to the other assessment years.
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