Permanent-establishment reassessment cannot revisit scrutinised disclosures; extended reopening fails without undisclosed material facts and within st...
Modified returns after business reorganisation must be assessed within pending proceedings, barring parallel scrutiny and consequential transfer prici...
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.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4897 
