Supervisory permanent establishment requires project-wise duration and qualifying construction nexus; offshore supplies and salary reimbursements rema...
Transfer-pricing comparability permits fresh objections and filters where software service comparables are functionally unsuitable for arm's-length pr...
Territorial rendering requirement excludes China-based management and consultancy services from fees for technical services under the India-China DTAA...
Section 43B(e) was held inapplicable to interest payable by a co-operative society on deposits from its own members, because the clause covers only interest on loans or advances from the specified institutions. The liability had accrued during the year and was recorded under the governing co-operative law, so the expenditure was allowable on accrual basis under section 37(1). The Tribunal also noted that the assessee's entitlement to deduction under section 80P(2)(a)(i) had already been affirmed, and any enhanced business profits arising from the disallowance would also qualify for deduction under section 80P. The addition was deleted.
Section 43B(e) was held inapplicable to interest payable by a co-operative society on deposits from its own members, because the clause covers only interest on loans or advances from the specified institutions. The liability had accrued during the year and was recorded under the governing co-operative law, so the expenditure was allowable on accrual basis under section 37(1). The Tribunal also noted that the assessee's entitlement to deduction under section 80P(2)(a)(i) had already been affirmed, and any enhanced business profits arising from the disallowance would also qualify for deduction under section 80P. The addition was deleted.
Note: It is a system-generated summary and is for quick reference only.