Functional comparability under TNMM supported exclusion of ITeS comparables with R&D, intangibles, diversified operations, or unavailable segmental da...
Functional comparability governs selection of support-service and IT-enabled service comparables, with verification required for unresolved data and m...
Bank account freezing requires statutory authority; anti-money-laundering compliance and KYC monitoring do not permit unilateral indefinite restrictio...
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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