Transfer-pricing treatment of ITeS margins excludes pass-through tax recoveries and separate delayed-receivables interest after working-capital adjust...
Capacity-utilisation adjustments under TNMM can neutralise substantiated COVID-related idle costs where underutilisation materially affects profitabil...
TNMM functional comparability requires excluding rice manufacturers from a pure Basmati rice trader's benchmark and recognising operating export recei...
Working-capital adjustment subsumes delayed-receivable effects in TNMM benchmarking of captive software-development services, avoiding separate notion...
Transfer-pricing comparability requires exclusion of financially illogical super-profit comparables and correction of unsupported annual-report and ma...
Charitable character assessment preserves Section 80G approval despite inclusive spiritual teachings and incidental religious expenditure within the s...
Penalty proceedings for cash-loan acceptance require assessment proceedings and recorded Assessing Officer satisfaction; absent these, the proceedings...
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Revision u/s 263 - Deduction u/s 80P on interest received from Cooperative Bank - After considering the submissions and the relevant statutory provisions and precedents, the Appellate Tribunal upheld the Revision order passed by the PCIT under section 263. The Tribunal concluded that interest earned from investments made in any bank, including cooperative banks, is not deductible under section 80P(2)(d) of the Income Tax Act, in accordance with the decision of the Hon. Gujarat High Court in Katlary Kariyana case.
Revision u/s 263 - Deduction u/s 80P on interest received from Cooperative Bank - After considering the submissions and the relevant statutory provisions and precedents, the Appellate Tribunal upheld the Revision order passed by the PCIT under section 263. The Tribunal concluded that interest earned from investments made in any bank, including cooperative banks, is not deductible under section 80P(2)(d) of the Income Tax Act, in accordance with the decision of the Hon. Gujarat High Court in Katlary Kariyana case.
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