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...
Deduction u/s 80P(2)(a)(i) - The decision underscores the principle that interest income earned by co-operative societies, if invested in compliance with statutory requirements, can be classified as 'income from business', qualifying for deductions under the Income Tax Act. It further mandates examination of such income under various provisions (sections 80P(2)(a)(i), 80P(2)(d), and 57) to determine the appropriate tax treatment. The AO is directed to assess the nature of such income and applicable deductions, based on statutory compliance and relevant judicial pronouncements. - AT
Deduction u/s 80P(2)(a)(i) - The decision underscores the principle that interest income earned by co-operative societies, if invested in compliance with statutory requirements, can be classified as 'income from business', qualifying for deductions under the Income Tax Act. It further mandates examination of such income under various provisions (sections 80P(2)(a)(i), 80P(2)(d), and 57) to determine the appropriate tax treatment. The AO is directed to assess the nature of such income and applicable deductions, based on statutory compliance and relevant judicial pronouncements. - AT
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