Dispute Resolution Panel objections must reach both prescribed forums; otherwise assessment may proceed and statutory appeal remains the proper remedy...
Political contribution deductions require recipient party compliance with contribution-reporting conditions; banking-channel donations alone do not qu...
Aggregation under TNMM prevents selective testing of intra-group services without comparable uncontrolled transactions, while appellate additional cla...
Protective assessment cannot duplicate identical receipts under competing characterisations; remote services did not establish a taxable permanent est...
Co-operative bank registered under state Act, main objective providing credit facility to members who are employees, funds contributed by members given as loans on interest to members only. Principal business not banking as no transactions with general public. First and third conditions for categorization as co-operative or primary co-operative bank not met, hence not hit by Section 80P(4) disallowing deduction. Small portion of income from interest on investments and dividend, eligible for deduction u/s 80P(2)(d). Remaining income from interest from members on deposits attributable to business income, deductible u/s 80P(2)(a)(i). Authorities not justified in denying Section 80P deduction to assessee society.
Co-operative bank registered under state Act, main objective providing credit facility to members who are employees, funds contributed by members given as loans on interest to members only. Principal business not banking as no transactions with general public. First and third conditions for categorization as co-operative or primary co-operative bank not met, hence not hit by Section 80P(4) disallowing deduction. Small portion of income from interest on investments and dividend, eligible for deduction u/s 80P(2)(d). Remaining income from interest from members on deposits attributable to business income, deductible u/s 80P(2)(a)(i). Authorities not justified in denying Section 80P deduction to assessee society.
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