Transfer pricing requires evidence for AMP transactions, functionally reliable comparables, and appropriate aggregation or Berry Ratio benchmarking me...
Revisionary jurisdiction cannot reopen share capital assessments where adequate inquiry supports a permissible view and no independent error is establ...
Reassessment jurisdiction fails where unverified portal information is aggregated without examining the taxpayer's explanation or relevance of entries...
Statutory sanction for delayed reassessment requires approval from the prescribed authority; approval by an inferior authority invalidates jurisdictio...
Transfer pricing margin adjustments require matching treatment of non-operating income and related costs, with comparability issues reconsidered on ev...
Preliminary-expense amortisation and MAT exempt-income adjustments prevailed, while trademark costs and managerial remuneration require fresh verifica...
Export valuation requires contemporaneous evidence; unrelated invoices cannot prove overvaluation, and dual penalties on firm and partner are impermis...
Disallowance of deduction(s) u/s 80P - interest income from the investments made in co-operative/other bank(s) - The tribunal analyzed Sec. 80P(2)(d) and determined that interest income derived by a cooperative society from investments made with any other cooperative society is eligible for deduction. Despite an amendment excluding co-operative banks from Sec. 80P benefits, the tribunal held that as long as the interest income is derived from investments with a cooperative bank, the deduction is permissible.
Disallowance of deduction(s) u/s 80P - interest income from the investments made in co-operative/other bank(s) - The tribunal analyzed Sec. 80P(2)(d) and determined that interest income derived by a cooperative society from investments made with any other cooperative society is eligible for deduction. Despite an amendment excluding co-operative banks from Sec. 80P benefits, the tribunal held that as long as the interest income is derived from investments with a cooperative bank, the deduction is permissible.
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