Development agreements require legal possession or effective enjoyment for capital gains transfer; permissive possession and deferred consideration de...
Prolonged sterilisation of development rights supports capital-gains treatment, while business-income disallowances cannot govern capital-gains comput...
Additional evidence in transfer pricing dispute leads to fresh examination, while tax deductions, TDS credit, fee and refund interest require verifica...
Category II AIF pass-through taxation preserves non-business income character; investment receipts cannot be reclassified without applying recognised ...
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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