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...
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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