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 from investments with a co-operative bank qualified for deduction under section 80P(2)(d). The Tribunal followed the Gujarat HC ruling in PCIT v. Ashwinkumar Arban Co-operative Society Ltd., holding that a co-operative bank remains a co-operative society for this purpose and that the exclusion in section 80P(4) does not prevent another co-operative society from claiming the deduction on such interest income. The disallowance was therefore unsustainable and the deduction claim was upheld on merits.
Interest earned by a co-operative society from investments with a co-operative bank qualified for deduction under section 80P(2)(d). The Tribunal followed the Gujarat HC ruling in PCIT v. Ashwinkumar Arban Co-operative Society Ltd., holding that a co-operative bank remains a co-operative society for this purpose and that the exclusion in section 80P(4) does not prevent another co-operative society from claiming the deduction on such interest income. The disallowance was therefore unsustainable and the deduction claim was upheld on merits.
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