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 - interest income - The tribunal noted that section 80P(2)(a)(i) allows deduction for cooperative societies engaged in banking or providing credit facilities to members. - The tribunal distinguished the facts of the present case from the decision of the Supreme Court in Totgars Co-operative Sale Society Ltd. The tribunal observed that the income in question was derived from activities eligible for deduction under section 80P. - Citing judgments of the Andhra Pradesh High Court and a coordinate Bench of the Tribunal, the tribunal held that interest income derived from activities listed in section 80P(2)(a) qualifies for deduction under section 80P.
Deduction u/s 80P - interest income - The tribunal noted that section 80P(2)(a)(i) allows deduction for cooperative societies engaged in banking or providing credit facilities to members. - The tribunal distinguished the facts of the present case from the decision of the Supreme Court in Totgars Co-operative Sale Society Ltd. The tribunal observed that the income in question was derived from activities eligible for deduction under section 80P. - Citing judgments of the Andhra Pradesh High Court and a coordinate Bench of the Tribunal, the tribunal held that interest income derived from activities listed in section 80P(2)(a) qualifies for deduction under section 80P.
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