Transfer pricing comparables and operating income principles applied to software development services, with exclusions, inclusions, and tax credit ver...
Transfer pricing on performance guarantees and overdue receivables deleted where warranty obligations were embedded and working capital adjustment alr...
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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