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 - deduction of income earned as interest/dividend from co-operative bank is allowable. Section 80P(2)(d) reflects that if income by way of interest or dividend is derived by the Co-operative Society from its investment with any other Co-operative Society, the whole of such income shall be deducted in computing the total income. Income by way of interest or dividend earned from investment with any other Co-operative Society, including Co-operative Banks, is deductible in computing the total income. Coordinate Benches of the Tribunal have allowed deduction for interest/dividend income earned from Co-operative Banks u/s 80P(2)(d). The Assessing Officer is directed to allow deduction for interest earned from Co-operative Banks, subject to verification.
Deduction u/s 80P - deduction of income earned as interest/dividend from co-operative bank is allowable. Section 80P(2)(d) reflects that if income by way of interest or dividend is derived by the Co-operative Society from its investment with any other Co-operative Society, the whole of such income shall be deducted in computing the total income. Income by way of interest or dividend earned from investment with any other Co-operative Society, including Co-operative Banks, is deductible in computing the total income. Coordinate Benches of the Tribunal have allowed deduction for interest/dividend income earned from Co-operative Banks u/s 80P(2)(d). The Assessing Officer is directed to allow deduction for interest earned from Co-operative Banks, subject to verification.
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