Pre-amendment reassessment limitation bars late notices under the preserved regime, invalidating consequential reassessment for affected earlier asses...
Cash-sales explanations for bank deposits require documentary reconciliation; reassessment notice survived where effective response time was available...
Functional comparability in transfer pricing prevents ad hoc arm's length adjustments where functions, assets, risks and reliable comparables are unes...
Contingency expenses, exempt-income disallowance, and royalty benchmarking: unsupported adjustments were deleted under consistent accounting and trans...
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ITAT held that deduction under section 80P(2)(d) is not allowable for interest income earned from investments with cooperative banks. The tribunal ruled that exemption provisions must be strictly interpreted and distinguished cooperative banks from cooperative societies per se. Relying on Karnataka High Court precedents in Bangalore Club and Totagars cases, which followed Supreme Court judgment, ITAT determined that cooperative banks are treated at par with scheduled banks under sub-section (4) of section 80P. The deduction is available only for interest received from cooperative societies, not cooperative banks. Revenue's appeal was allowed, CIT(A)'s order was set aside, and AO's order was confirmed.
ITAT held that deduction under section 80P(2)(d) is not allowable for interest income earned from investments with cooperative banks. The tribunal ruled that exemption provisions must be strictly interpreted and distinguished cooperative banks from cooperative societies per se. Relying on Karnataka High Court precedents in Bangalore Club and Totagars cases, which followed Supreme Court judgment, ITAT determined that cooperative banks are treated at par with scheduled banks under sub-section (4) of section 80P. The deduction is available only for interest received from cooperative societies, not cooperative banks. Revenue's appeal was allowed, CIT(A)'s order was set aside, and AO's order was confirmed.
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