Section 80P deduction covers Souharda credit societies, including qualifying surplus-deposit interest, subject to member KYC verification for cash dep...
Transfer-pricing benchmarking and capital-receipt principles sustained taxpayer relief, while unsupported property-advance write-offs remained disallo...
The ITAT Visakhapatnam considered whether the appellant, an entity established under the APSCHE Act, qualifies as an 'instrument of state' u/s Article 12 of the Constitution for tax exemption. The tribunal found that the appellant, under full control of the State Government, meets the criteria of an instrumentality of the government. The concept of 'other authorities' in Article 12 was analyzed, referencing the Supreme Court's tests from the Som Prakash Rekhi case. The tribunal concluded that the appellant, being under the superintendence and control of the State Government, falls within the definition of 'State' u/s Article 12, entitling it to immunity from taxation. The appellant's appeal was allowed, emphasizing full tax exemption for its income and receipts.
The ITAT Visakhapatnam considered whether the appellant, an entity established under the APSCHE Act, qualifies as an 'instrument of state' u/s Article 12 of the Constitution for tax exemption. The tribunal found that the appellant, under full control of the State Government, meets the criteria of an instrumentality of the government. The concept of 'other authorities' in Article 12 was analyzed, referencing the Supreme Court's tests from the Som Prakash Rekhi case. The tribunal concluded that the appellant, being under the superintendence and control of the State Government, falls within the definition of 'State' u/s Article 12, entitling it to immunity from taxation. The appellant's appeal was allowed, emphasizing full tax exemption for its income and receipts.
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