Reopening of assessment cannot rest solely on an audit party's opinion; reassessment under Section 147/148 is impermissible and power of revision shou...
Tested party selection: functional analysis identified the least complex unit as the appropriate tested party, altering the transfer pricing adjustmen...
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.
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