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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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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