Reopening of assessment cannot rest solely on an audit party's opinion; reassessment under Section 147/148 is impermissible and power of revision shou...
Tested party selection: functional analysis identified the least complex unit as the appropriate tested party, altering the transfer pricing adjustmen...
Commission income earned for collecting bills, dues and charges on behalf of a public utility is treated as akin to banking activity and, being incidental to the society's main objects, qualifies for the cooperative-society deduction under the relevant 80P provision; accordingly the claim for deduction in respect of commission received from the public utility was allowed and the appeal permitted. The note emphasises applicability of prior Tribunal precedent equating collection-of-dues activity with banking activity as determinative of entitlement.
Commission income earned for collecting bills, dues and charges on behalf of a public utility is treated as akin to banking activity and, being incidental to the society's main objects, qualifies for the cooperative-society deduction under the relevant 80P provision; accordingly the claim for deduction in respect of commission received from the public utility was allowed and the appeal permitted. The note emphasises applicability of prior Tribunal precedent equating collection-of-dues activity with banking activity as determinative of entitlement.
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