Section 80JJAA employee-cost deduction allowed for deployed staff but barred against transfer-pricing income enhancement, with pricing issues remanded...
Transfer-pricing methodology protects commercially genuine associated-enterprise payments, while pre-2016 secondary adjustments and related notional i...
Negative liens over operating assets can constitute international transactions requiring arm's-length pricing reflecting restricted borrowing and expa...
Cross-examination rights in Customs Broker revocation inquiries require witness examination; procedural denial may be cured through fresh adjudication...
Governmental authority status supports construction-service exemption, while pre-cutoff contract and stamp-duty compliance requires verification on re...
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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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