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...
Eligibility of Deduction u/s 80P - bank interest earned from cooperative banks - The Appellate Tribunal found that even if the interest income is not considered as business income, the deduction cannot be denied under Section 80P(2)(d) of the Act. The Tribunal referred to the decision of the Supreme Court in the case of Kerala State Co-Operative Agricultural & Rural Development Bank Ltd., where deduction was allowed to a cooperative engaged in providing credit facilities to its members. The Tribunal held that the appellant, being a cooperative society of employees of a corporation, is entitled to the deduction under Section 80P(2)(d) of the Act.
Eligibility of Deduction u/s 80P - bank interest earned from cooperative banks - The Appellate Tribunal found that even if the interest income is not considered as business income, the deduction cannot be denied under Section 80P(2)(d) of the Act. The Tribunal referred to the decision of the Supreme Court in the case of Kerala State Co-Operative Agricultural & Rural Development Bank Ltd., where deduction was allowed to a cooperative engaged in providing credit facilities to its members. The Tribunal held that the appellant, being a cooperative society of employees of a corporation, is entitled to the deduction under Section 80P(2)(d) of the Act.
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