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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The ITAT denied deduction under Sec. 80P(2)(a)(i) to a cooperative society acting as a cooperative bank. However, citing precedents, it allowed deduction for interest income on surplus funds parked as deposits. The ITAT directed the AO to allow the deduction. Regarding paddy procurement business, the ITAT found the restriction of deduction under Sec. 80P(2)(a)(iii) unjustified due to new evidence. The matter was remanded for fresh adjudication based on the extent of facilitation provided to non-members. The ITAT allowed deduction for dividend income on shares of a cooperative bank under Sec. 80P(2)(d), aligning with previous rulings.
The ITAT denied deduction under Sec. 80P(2)(a)(i) to a cooperative society acting as a cooperative bank. However, citing precedents, it allowed deduction for interest income on surplus funds parked as deposits. The ITAT directed the AO to allow the deduction. Regarding paddy procurement business, the ITAT found the restriction of deduction under Sec. 80P(2)(a)(iii) unjustified due to new evidence. The matter was remanded for fresh adjudication based on the extent of facilitation provided to non-members. The ITAT allowed deduction for dividend income on shares of a cooperative bank under Sec. 80P(2)(d), aligning with previous rulings.
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