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 remitted the matter to the file of the AO for determination and computation of business income, income from other sources and entitlement to deduction under s.80P. The Tribunal held: interest derived exclusively from credit facilities to members constitutes operating profit of the co-operative society and is deductible under s.80P(2)(a)(i); interest on statutory deposits/maintenance of fluid resources is attributable to business and deductible under s.80P(2)(a)(i) irrespective of bank category; interest on investments in entities qualifying as a "banking company" (per statutory definition and licencing) in excess of statutory limits is income from other sources and not eligible for s.80P(2)(d), though fund-cost and related administrative expenses are allowable under s.57; interest or dividends from investments in other co-operative societies are fully deductible under s.80P(2)(d); idle surplus fund interest beyond statutory requirements is not business income and not deductible under s.80P(2)(a)(i).
ITAT remitted the matter to the file of the AO for determination and computation of business income, income from other sources and entitlement to deduction under s.80P. The Tribunal held: interest derived exclusively from credit facilities to members constitutes operating profit of the co-operative society and is deductible under s.80P(2)(a)(i); interest on statutory deposits/maintenance of fluid resources is attributable to business and deductible under s.80P(2)(a)(i) irrespective of bank category; interest on investments in entities qualifying as a "banking company" (per statutory definition and licencing) in excess of statutory limits is income from other sources and not eligible for s.80P(2)(d), though fund-cost and related administrative expenses are allowable under s.57; interest or dividends from investments in other co-operative societies are fully deductible under s.80P(2)(d); idle surplus fund interest beyond statutory requirements is not business income and not deductible under s.80P(2)(a)(i).
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