Transfer-pricing treatment of ITeS margins excludes pass-through tax recoveries and separate delayed-receivables interest after working-capital adjust...
Capacity-utilisation adjustments under TNMM can neutralise substantiated COVID-related idle costs where underutilisation materially affects profitabil...
TNMM functional comparability requires excluding rice manufacturers from a pure Basmati rice trader's benchmark and recognising operating export recei...
Working-capital adjustment subsumes delayed-receivable effects in TNMM benchmarking of captive software-development services, avoiding separate notion...
Transfer-pricing comparability requires exclusion of financially illogical super-profit comparables and correction of unsupported annual-report and ma...
Charitable character assessment preserves Section 80G approval despite inclusive spiritual teachings and incidental religious expenditure within the s...
Penalty proceedings for cash-loan acceptance require assessment proceedings and recorded Assessing Officer satisfaction; absent these, the proceedings...
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Interest on income-tax refund received by a co-operative society was treated as income attributable to its banking activity for members, so deduction under section 80P(2)(a)(i) was allowed. Relying on Special Bench precedent, the Tribunal rejected the view that the receipt was income from other sources. The addition on this account was deleted and the assessee's deduction claim was accepted.
Interest on income-tax refund received by a co-operative society was treated as income attributable to its banking activity for members, so deduction under section 80P(2)(a)(i) was allowed. Relying on Special Bench precedent, the Tribunal rejected the view that the receipt was income from other sources. The addition on this account was deleted and the assessee's deduction claim was accepted.
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