Pre-amendment reassessment limitation bars late notices under the preserved regime, invalidating consequential reassessment for affected earlier asses...
Cash-sales explanations for bank deposits require documentary reconciliation; reassessment notice survived where effective response time was available...
Functional comparability in transfer pricing prevents ad hoc arm's length adjustments where functions, assets, risks and reliable comparables are unes...
Denial of 80P(2)(a)(i) deduction - interest income - The Tribunal acknowledged the appellant's argument that the interest earned on deposits from a reserve fund constituted business income derived from providing credit facilities to members, thus qualifying for deductions u/s80P(2)(a)(i). - However, following precedent set by the Hon'ble Karnataka High Court and various other rulings, the Tribunal ruled that interest income from deposits held in banks does not change its nature as income from other sources, regardless of the entity type from which the interest is received. The Tribunal also directed the assessing officer to consider the proportionate costs and administrative expenses incurred in generating the interest income, thereby allowing a partial relief to the assessee.
Denial of 80P(2)(a)(i) deduction - interest income - The Tribunal acknowledged the appellant's argument that the interest earned on deposits from a reserve fund constituted business income derived from providing credit facilities to members, thus qualifying for deductions u/s80P(2)(a)(i). - However, following precedent set by the Hon'ble Karnataka High Court and various other rulings, the Tribunal ruled that interest income from deposits held in banks does not change its nature as income from other sources, regardless of the entity type from which the interest is received. The Tribunal also directed the assessing officer to consider the proportionate costs and administrative expenses incurred in generating the interest income, thereby allowing a partial relief to the assessee.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4918 
