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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...
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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