Infrastructure-development deduction remains available to EPC contractors when substantive statutory conditions outweigh contractor labels in agreemen...
Explained Investment Sources: documented gifts and traceable salary savings supported deletion of additions for property and mutual-fund SIP investmen...
Internal comparable pricing supports arm's-length interest on compulsorily convertible debentures, preventing their recharacterisation as equity for t...
Nominee director protection shields independent financial-institution appointees from criminal liability where they lack involvement in deposit defaul...
Regional Rural Banks are deemed to be co-operative societies for Income-tax Act purposes under the statutory fiction in section 22 of the Regional Rural Banks Act. That fiction remains effective because section 80P(4) does not displace it, and definitions of primary co-operative bank or primary credit society are inapplicable where the bank is not claimed to fall within those categories. Deduction under section 80P is therefore available. An assessment correctly granting that deduction is not erroneous and prejudicial to the interests of the Revenue, limiting revision under section 263.
Regional Rural Banks are deemed to be co-operative societies for Income-tax Act purposes under the statutory fiction in section 22 of the Regional Rural Banks Act. That fiction remains effective because section 80P(4) does not displace it, and definitions of primary co-operative bank or primary credit society are inapplicable where the bank is not claimed to fall within those categories. Deduction under section 80P is therefore available. An assessment correctly granting that deduction is not erroneous and prejudicial to the interests of the Revenue, limiting revision under section 263.
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