Approved resolution plans extinguish unsubmitted pre-approval tax claims, preventing later recovery outside the insolvency process and preserving a cl...
Transfer pricing comparability requires functional alignment and permits working capital adjustment, while APA margins cannot govern non-covered years...
Treaty benefit, goodwill depreciation and hedging costs: export commission disallowed, while key business deductions and depreciation claims succeeded...
Undisclosed foreign asset classification requires an unexplained source; unrebutted affidavits and corroborative evidence defeated the Black Money Act...
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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