Working-capital adjustment determines whether software-services transfer-pricing margins fall within the statutory tolerance range, eliminating any ad...
Permanent establishment deductions upheld for expatriate salaries, direct costs and trading losses, while head-office costs require fresh classificati...
Data transmission equipment classification under CTSH 8517 62 remains distinct from residual classification, with exemption evidence requiring scrutin...
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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