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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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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