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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Deduction claimed u/s. 80P(2)(a)(i) - Status showing as AOP and not mentioned as cooperative society - The Tribunal referred to the definition of "person" under section 2(31) of the Income Tax Act. It noted that there was no separate status specified for cooperative societies. Since there was no specific status for cooperative societies, mentioning the status as AOP did not disqualify the assessee from claiming the deduction under section 80P(2)(a)(i). The Tribunal also cited a precedent where a similar issue was addressed by a co-ordinate bench, which allowed the deduction for a cooperative society even though the status mentioned was AOP. - AO directed to allow the deduction as claimed under section 80P(2)(a)(i) of the Income Tax Act.
Deduction claimed u/s. 80P(2)(a)(i) - Status showing as AOP and not mentioned as cooperative society - The Tribunal referred to the definition of "person" under section 2(31) of the Income Tax Act. It noted that there was no separate status specified for cooperative societies. Since there was no specific status for cooperative societies, mentioning the status as AOP did not disqualify the assessee from claiming the deduction under section 80P(2)(a)(i). The Tribunal also cited a precedent where a similar issue was addressed by a co-ordinate bench, which allowed the deduction for a cooperative society even though the status mentioned was AOP. - AO directed to allow the deduction as claimed under section 80P(2)(a)(i) of the Income Tax Act.
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