Allocation of registration charges: contractual clause overriding statutory presumption allowed as deduction against capital gain after unrebutted doc...
Expenditure tied to investments yielding exempt income restricted to attributable costs; broader disallowance disallowed and adjustments to WDV and mi...
Admissibility of Investigative Statements invalidated reliance on coerced emails and valuation redetermination, resulting in set aside of penalties an...
Classification of printed technical documents: specific Chapter 49.01 entry prevails, enabling claimed customs exemptions for imported manuals and rep...
Section 80P(2)(d) permits a co-operative society to claim deduction for interest derived from investments with another co-operative society, and section 80P(4) bars only a co-operative bank from claiming deduction in its own right. The ITAT applied this distinction to interest earned by a co-operative society from deposits placed with co-operative banks, following Sikkim State Cooperative Supply and Marketing Federation and distinguishing Totgars as a case under section 80P(2)(a)(i). It also relied on Doaba Cooperative Sugar Mills to hold that the source of invested funds was not decisive where the income arose from investment with a co-operative society. The disallowance was held unsustainable and the deduction was allowed.
Section 80P(2)(d) permits a co-operative society to claim deduction for interest derived from investments with another co-operative society, and section 80P(4) bars only a co-operative bank from claiming deduction in its own right. The ITAT applied this distinction to interest earned by a co-operative society from deposits placed with co-operative banks, following Sikkim State Cooperative Supply and Marketing Federation and distinguishing Totgars as a case under section 80P(2)(a)(i). It also relied on Doaba Cooperative Sugar Mills to hold that the source of invested funds was not decisive where the income arose from investment with a co-operative society. The disallowance was held unsustainable and the deduction was allowed.
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