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 us/ 80P(2) - income received on investment made with co-operative banks - The Tribunal interpreted section 80P(2)(d) and (e) to determine the eligibility of the appellant's income for deduction. It concluded that the income derived from the appellant's investments with DCCB did not fall under section 80P(2)(d) as it was not from investments with other cooperative societies. Therefore, the Tribunal upheld the appellant's eligibility for deduction u/s 80P(2)(a)(i) of the Act.
Deduction us/ 80P(2) - income received on investment made with co-operative banks - The Tribunal interpreted section 80P(2)(d) and (e) to determine the eligibility of the appellant's income for deduction. It concluded that the income derived from the appellant's investments with DCCB did not fall under section 80P(2)(d) as it was not from investments with other cooperative societies. Therefore, the Tribunal upheld the appellant's eligibility for deduction u/s 80P(2)(a)(i) of the Act.
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