Pure-agent exclusion fails where hotel booking facilitators receive third-party services themselves, making entire customer consideration taxable as r...
Transfer pricing requires evidence for AMP transactions, functionally reliable comparables, and appropriate aggregation or Berry Ratio benchmarking me...
Revisionary jurisdiction cannot reopen share capital assessments where adequate inquiry supports a permissible view and no independent error is establ...
Reassessment jurisdiction fails where unverified portal information is aggregated without examining the taxpayer's explanation or relevance of entries...
Statutory sanction for delayed reassessment requires approval from the prescribed authority; approval by an inferior authority invalidates jurisdictio...
Transfer pricing margin adjustments require matching treatment of non-operating income and related costs, with comparability issues reconsidered on ev...
Preliminary-expense amortisation and MAT exempt-income adjustments prevailed, while trademark costs and managerial remuneration require fresh verifica...
Export valuation requires contemporaneous evidence; unrelated invoices cannot prove overvaluation, and dual penalties on firm and partner are impermis...
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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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