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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Interest income earned by a cooperative society from deposits made with another cooperative bank is eligible for deduction u/s 80P(2)(d) of the Income Tax Act. The provision unambiguously allows deduction for interest income derived from investments with other cooperative societies. Therefore, the appellant cooperative society is entitled to claim deduction u/s 80P(2)(d) for the interest received from the Punjab State Cooperative Agricultural Development Bank. However, the excess contribution made by the appellant to the Gratuity Fund, over and above the permissible limit of 8.33% under the applicable rules, has been rightly disallowed and added back to its total income under the head "Income from Other Sources" by the tax authorities.
Interest income earned by a cooperative society from deposits made with another cooperative bank is eligible for deduction u/s 80P(2)(d) of the Income Tax Act. The provision unambiguously allows deduction for interest income derived from investments with other cooperative societies. Therefore, the appellant cooperative society is entitled to claim deduction u/s 80P(2)(d) for the interest received from the Punjab State Cooperative Agricultural Development Bank. However, the excess contribution made by the appellant to the Gratuity Fund, over and above the permissible limit of 8.33% under the applicable rules, has been rightly disallowed and added back to its total income under the head "Income from Other Sources" by the tax authorities.
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