Service permanent establishment requires non-auxiliary services, while arm's-length distributor remuneration precludes further profit attribution in I...
Make-available condition excludes standard SaaS subscription receipts where customers receive no independently usable technical knowledge after subscr...
Anonymous donation classification fails where charitable trusts maintain undisputed donor identity records and evidence corpus contributions' intended...
Transfer pricing method selection favours TNMM where medical-equipment distribution involves substantial post-import value addition and operational ri...
Denial of deduction claimed u/s 80P (2)(d) - AO disallowed the benefit by invoking the provision of section 154 for rectification of mistake change of opinion - interest derived by the Co-operative society from its investments with any other co-operative society - The ITAT held that considering the provisions of section 22 of Regional Rural Bank Act, wherein the status of the banks established are of the co-operative society the assessee is entitled for the exemption on the interest earned on the deposits. - The allowability of deduction of interest u/s. 80P(2)(d) decided in favour of assessee on merit itslef.
Denial of deduction claimed u/s 80P (2)(d) - AO disallowed the benefit by invoking the provision of section 154 for rectification of mistake change of opinion - interest derived by the Co-operative society from its investments with any other co-operative society - The ITAT held that considering the provisions of section 22 of Regional Rural Bank Act, wherein the status of the banks established are of the co-operative society the assessee is entitled for the exemption on the interest earned on the deposits. - The allowability of deduction of interest u/s. 80P(2)(d) decided in favour of assessee on merit itslef.
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