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Negative liens over operating assets can constitute international transactions requiring arm's-length pricing reflecting restricted borrowing and expa...
Cross-examination rights in Customs Broker revocation inquiries require witness examination; procedural denial may be cured through fresh adjudication...
The Appellate Tribunal addressed the following issues: 1. Deduction u/s. 80P(1) r.w.s. 80P(2)(a)(i) - Held that the assessee is not a cooperative bank, making it eligible for the deduction for AY 2010-11 and 2011-12. No changes in bye-laws post 31/3/2007 were noted. The denial of deduction by Revenue authorities based on the assessee being a cooperative bank was overturned. 2. Payment to staff retirement benefit - Disallowed u/s. 36(1)(iv)/(v) due to unapproved fund. Disallowance would be absorbed in the deduction u/s. 80P(1) against gross total income. 3. Interest on income tax refund - Confirmed as income from other sources u/s. 56, not eligible for deduction u/s. 80P.
The Appellate Tribunal addressed the following issues: 1. Deduction u/s. 80P(1) r.w.s. 80P(2)(a)(i) - Held that the assessee is not a cooperative bank, making it eligible for the deduction for AY 2010-11 and 2011-12. No changes in bye-laws post 31/3/2007 were noted. The denial of deduction by Revenue authorities based on the assessee being a cooperative bank was overturned. 2. Payment to staff retirement benefit - Disallowed u/s. 36(1)(iv)/(v) due to unapproved fund. Disallowance would be absorbed in the deduction u/s. 80P(1) against gross total income. 3. Interest on income tax refund - Confirmed as income from other sources u/s. 56, not eligible for deduction u/s. 80P.
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