Transfer pricing comparables and operating income principles applied to software development services, with exclusions, inclusions, and tax credit ver...
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Interest earned on short-term bank deposits of surplus funds retained its character as income attributable to the business of providing credit facilities to members, so it qualified for deduction under section 80P(2)(a)(i). Applying Tumkur Merchants Souharda Credit Cooperative Ltd., the Tribunal held that temporary investment of funds not immediately required for lending does not convert such interest into income from other sources. It also distinguished the Totgars decisions, noting they concerned section 80P(2)(d) and were not governing on the facts. The lower authorities' denial of deduction was held erroneous, and the deduction was directed to be allowed.
Interest earned on short-term bank deposits of surplus funds retained its character as income attributable to the business of providing credit facilities to members, so it qualified for deduction under section 80P(2)(a)(i). Applying Tumkur Merchants Souharda Credit Cooperative Ltd., the Tribunal held that temporary investment of funds not immediately required for lending does not convert such interest into income from other sources. It also distinguished the Totgars decisions, noting they concerned section 80P(2)(d) and were not governing on the facts. The lower authorities' denial of deduction was held erroneous, and the deduction was directed to be allowed.
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