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...
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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