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 u/s 80P(2)(d) was denied through intimation u/s 143(1) on interest income earned by the assessee from cooperative banks. The Tribunal held that neither the assessee's claim u/s 80P was inconsistent with another entry nor did the deduction exceed the statutory limit, making it an allowable claim. Disallowance of deduction u/s 80P(2)(d) is not permitted u/s 143(1). On merits, the interest was earned from cooperative banks, which are cooperative societies registered under relevant laws and engaged in banking business. The assessee satisfied all conditions u/s 80P(2)(d) for deduction on interest income from cooperative banks. The Tribunal decided in favor of the assessee.
Deduction u/s 80P(2)(d) was denied through intimation u/s 143(1) on interest income earned by the assessee from cooperative banks. The Tribunal held that neither the assessee's claim u/s 80P was inconsistent with another entry nor did the deduction exceed the statutory limit, making it an allowable claim. Disallowance of deduction u/s 80P(2)(d) is not permitted u/s 143(1). On merits, the interest was earned from cooperative banks, which are cooperative societies registered under relevant laws and engaged in banking business. The assessee satisfied all conditions u/s 80P(2)(d) for deduction on interest income from cooperative banks. The Tribunal decided in favor of the assessee.
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