Revenue neutrality in domestic related-party loans can require deletion of interest transfer pricing adjustments after domestic-transaction verificati...
Pre-enactment land-sale agreements escape stamp-duty value substitution where substantial banking-channel consideration was received before Section 43...
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Directly relevant additional evidence supporting commission paid to daily deposit collection agents was admitted because the lower authorities had not examined it, and the commission disallowance was remanded for fresh consideration. Interest estimated on non-performing loans to members was deleted because income from credit facilities provided by a co-operative society to its members qualified for deduction under section 80P(2)(a)(i), rendering the addition revenue neutral. Interest estimated by applying a uniform rate across housing, mortgage, personal, deposit-backed and overdraft loans was also deleted because those loan categories carried differential rates and the resulting enhanced income would qualify for the same deduction. The appeal was partly allowed.
Directly relevant additional evidence supporting commission paid to daily deposit collection agents was admitted because the lower authorities had not examined it, and the commission disallowance was remanded for fresh consideration. Interest estimated on non-performing loans to members was deleted because income from credit facilities provided by a co-operative society to its members qualified for deduction under section 80P(2)(a)(i), rendering the addition revenue neutral. Interest estimated by applying a uniform rate across housing, mortgage, personal, deposit-backed and overdraft loans was also deleted because those loan categories carried differential rates and the resulting enhanced income would qualify for the same deduction. The appeal was partly allowed.
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