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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HC held that petitioner is a Co-operative Society and not a Co-operative Bank, despite cancellation of its banking licence in 2004. Applying binding SC precedent, the Court ruled that deduction under s.80P(2)(d) is available to a Co-operative Society on interest income from investments with a Co-operative Bank, which itself is a Co-operative Society. The reopening of assessment, premised on the contrary assumption that such deduction was not admissible, was found legally untenable. The impugned reopening notice was quashed and the matter decided in favour of the assessee.
HC held that petitioner is a Co-operative Society and not a Co-operative Bank, despite cancellation of its banking licence in 2004. Applying binding SC precedent, the Court ruled that deduction under s.80P(2)(d) is available to a Co-operative Society on interest income from investments with a Co-operative Bank, which itself is a Co-operative Society. The reopening of assessment, premised on the contrary assumption that such deduction was not admissible, was found legally untenable. The impugned reopening notice was quashed and the matter decided in favour of the assessee.
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