Section 80P deduction for co-operative societies remains available despite nominal members and housing society status, with limited interest income tr...
The branch office in India was treated as a continuation of the earlier liaison office, because the RBI approval and the nature of the upgraded arrangement showed an enlarged continuation of the existing presence rather than a new setup. On that basis, the Tribunal recorded that the branch office constituted a permanent establishment in India. As the taxability and profit attribution issues for the year were similar to those already remanded in earlier years, the matter was restored to the Assessing Officer for de novo examination, including the assessee's claim that the branch office served only the machinery division.
The branch office in India was treated as a continuation of the earlier liaison office, because the RBI approval and the nature of the upgraded arrangement showed an enlarged continuation of the existing presence rather than a new setup. On that basis, the Tribunal recorded that the branch office constituted a permanent establishment in India. As the taxability and profit attribution issues for the year were similar to those already remanded in earlier years, the matter was restored to the Assessing Officer for de novo examination, including the assessee's claim that the branch office served only the machinery division.
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