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...
Section 80P deductions for a co-operative credit society are addressed in relation to profits from providing credit facilities to members, interest income attributable to that activity, and any residual deduction where income remains. The notes state that disallowances require recorded reasons and that interest characterised as business income may qualify under section 80P(2)(a)(i), while an alternative claim under section 80P(2)(d) may not arise. Audit-fee provisions require evidence of an accrued, non-contingent liability. Leave-encashment provisions require proof of payment within the prescribed return-filing period. Member deposits require KYC particulars mandated by applicable co-operative law and RBI guidelines; absence of PAN alone is not decisive.
Section 80P deductions for a co-operative credit society are addressed in relation to profits from providing credit facilities to members, interest income attributable to that activity, and any residual deduction where income remains. The notes state that disallowances require recorded reasons and that interest characterised as business income may qualify under section 80P(2)(a)(i), while an alternative claim under section 80P(2)(d) may not arise. Audit-fee provisions require evidence of an accrued, non-contingent liability. Leave-encashment provisions require proof of payment within the prescribed return-filing period. Member deposits require KYC particulars mandated by applicable co-operative law and RBI guidelines; absence of PAN alone is not decisive.
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