Transfer-pricing treatment of ITeS margins excludes pass-through tax recoveries and separate delayed-receivables interest after working-capital adjust...
Capacity-utilisation adjustments under TNMM can neutralise substantiated COVID-related idle costs where underutilisation materially affects profitabil...
TNMM functional comparability requires excluding rice manufacturers from a pure Basmati rice trader's benchmark and recognising operating export recei...
Working-capital adjustment subsumes delayed-receivable effects in TNMM benchmarking of captive software-development services, avoiding separate notion...
Transfer-pricing comparability requires exclusion of financially illogical super-profit comparables and correction of unsupported annual-report and ma...
Charitable character assessment preserves Section 80G approval despite inclusive spiritual teachings and incidental religious expenditure within the s...
Penalty proceedings for cash-loan acceptance require assessment proceedings and recorded Assessing Officer satisfaction; absent these, the proceedings...
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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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