Development agreements require legal possession or effective enjoyment for capital gains transfer; permissive possession and deferred consideration de...
Prolonged sterilisation of development rights supports capital-gains treatment, while business-income disallowances cannot govern capital-gains comput...
Additional evidence in transfer pricing dispute leads to fresh examination, while tax deductions, TDS credit, fee and refund interest require verifica...
Category II AIF pass-through taxation preserves non-business income character; investment receipts cannot be reclassified without applying recognised ...
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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