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...
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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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Souharda Sahakaris registered under the Karnataka Souharda Sahakari Act, 1997 are treated as co-operative societies for deduction under section 80P. Where credit facilities are provided exclusively to members, income from that activity is attributable to the eligible business under section 80P(2)(a)(i), and dealings confined to members preserve mutuality. Interest earned by placing surplus funds, not immediately required for member lending, in bank deposits remains attributable to the credit-facility business rather than constituting a separate business. Such interest consequently forms part of the qualifying profits for the section 80P deduction.
Souharda Sahakaris registered under the Karnataka Souharda Sahakari Act, 1997 are treated as co-operative societies for deduction under section 80P. Where credit facilities are provided exclusively to members, income from that activity is attributable to the eligible business under section 80P(2)(a)(i), and dealings confined to members preserve mutuality. Interest earned by placing surplus funds, not immediately required for member lending, in bank deposits remains attributable to the credit-facility business rather than constituting a separate business. Such interest consequently forms part of the qualifying profits for the section 80P deduction.
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