Transfer pricing requires evidence for AMP transactions, functionally reliable comparables, and appropriate aggregation or Berry Ratio benchmarking me...
Revisionary jurisdiction cannot reopen share capital assessments where adequate inquiry supports a permissible view and no independent error is establ...
Reassessment jurisdiction fails where unverified portal information is aggregated without examining the taxpayer's explanation or relevance of entries...
Statutory sanction for delayed reassessment requires approval from the prescribed authority; approval by an inferior authority invalidates jurisdictio...
Transfer pricing margin adjustments require matching treatment of non-operating income and related costs, with comparability issues reconsidered on ev...
Preliminary-expense amortisation and MAT exempt-income adjustments prevailed, while trademark costs and managerial remuneration require fresh verifica...
Export valuation requires contemporaneous evidence; unrelated invoices cannot prove overvaluation, and dual penalties on firm and partner are impermis...
Interest earned by a co-operative housing society on fixed deposits with co-operative banks qualifies for deduction under section 80P(2)(d), provided the investment is with another co-operative society. A co-operative bank registered under applicable co-operative societies law remains a co-operative society for that purpose. Section 80P(4) restricts deductions claimed by co-operative banks themselves and does not limit the deduction available to an investing co-operative society. This interpretation is consistent with the liberal construction of beneficial provisions and Tribunal decisions applying the principle. The disallowance of the claimed deduction was deleted.
Interest earned by a co-operative housing society on fixed deposits with co-operative banks qualifies for deduction under section 80P(2)(d), provided the investment is with another co-operative society. A co-operative bank registered under applicable co-operative societies law remains a co-operative society for that purpose. Section 80P(4) restricts deductions claimed by co-operative banks themselves and does not limit the deduction available to an investing co-operative society. This interpretation is consistent with the liberal construction of beneficial provisions and Tribunal decisions applying the principle. The disallowance of the claimed deduction was deleted.
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