Service permanent establishment requires non-auxiliary services, while arm's-length distributor remuneration precludes further profit attribution in I...
Make-available condition excludes standard SaaS subscription receipts where customers receive no independently usable technical knowledge after subscr...
Anonymous donation classification fails where charitable trusts maintain undisputed donor identity records and evidence corpus contributions' intended...
Transfer pricing method selection favours TNMM where medical-equipment distribution involves substantial post-import value addition and operational ri...
Post-export shipping bill conversion remains available where contemporaneous evidence supports EPCG benefits despite curable procedural omissions and ...
Interest earned by a co-operative society on surplus funds placed with a co-operative bank was not deductible under section 80P(2)(a)(i) because the payer was not a member of the society and the income was assessable as income from other sources. However, the Tribunal found that the bank was registered as a co-operative society despite holding a banking licence, so the same interest qualified for deduction under section 80P(2)(d). The contrary view taken by the lower authorities was rejected, and the appeals were partly allowed for both assessment years.
Interest earned by a co-operative society on surplus funds placed with a co-operative bank was not deductible under section 80P(2)(a)(i) because the payer was not a member of the society and the income was assessable as income from other sources. However, the Tribunal found that the bank was registered as a co-operative society despite holding a banking licence, so the same interest qualified for deduction under section 80P(2)(d). The contrary view taken by the lower authorities was rejected, and the appeals were partly allowed for both assessment years.
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