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 from deposits placed with co-operative banks was held eligible for deduction because a co-operative bank was treated as a co-operative society for section 80P(2)(d). Revenue's reliance on Totgar's Co-operative Sale Society Ltd. was rejected as distinguishable on facts, since that precedent did not concern deposits with a co-operative society. On that basis, the disallowance made by the first appellate authority could not stand. The same reasoning was applied to the other two assessment years on identical facts, and deduction was allowed for all three years.
Interest earned from deposits placed with co-operative banks was held eligible for deduction because a co-operative bank was treated as a co-operative society for section 80P(2)(d). Revenue's reliance on Totgar's Co-operative Sale Society Ltd. was rejected as distinguishable on facts, since that precedent did not concern deposits with a co-operative society. On that basis, the disallowance made by the first appellate authority could not stand. The same reasoning was applied to the other two assessment years on identical facts, and deduction was allowed for all three years.
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