Transfer pricing comparability requires functional alignment and permits working capital adjustment, while APA margins cannot govern non-covered years...
Treaty benefit, goodwill depreciation and hedging costs: export commission disallowed, while key business deductions and depreciation claims succeeded...
Undisclosed foreign asset classification requires an unexplained source; unrebutted affidavits and corroborative evidence defeated the Black Money Act...
HC ruled that Section 194N of the Income Tax Act, 1961 applies comprehensively to cooperative banking societies, rejecting the petitioner's claim for exemption under Section 80P(2). The court determined that TDS deduction on loans and subsidies is mandatory, irrespective of the society's specialized agrarian service mandate. The court distinguished prior precedents based on factual variations and found the respondents' procedural actions legally sound. Consequently, the writ petition was dismissed, upholding the 2% TDS deduction and affirming the statutory interpretation that no blanket exemption exists for cooperative banking entities.
HC ruled that Section 194N of the Income Tax Act, 1961 applies comprehensively to cooperative banking societies, rejecting the petitioner's claim for exemption under Section 80P(2). The court determined that TDS deduction on loans and subsidies is mandatory, irrespective of the society's specialized agrarian service mandate. The court distinguished prior precedents based on factual variations and found the respondents' procedural actions legally sound. Consequently, the writ petition was dismissed, upholding the 2% TDS deduction and affirming the statutory interpretation that no blanket exemption exists for cooperative banking entities.
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