Donor-directed corpus contributions retain capital character despite exemption claims under section 10(23C)(vi), preventing their treatment as taxable...
Enhanced tax-audit threshold applies where banking records establish compliant non-cash receipts and payments, eliminating penalty exposure for audit ...
Transfer pricing consistency protects identical non-interest-bearing debenture terms from a later notional-interest adjustment without valid statutory...
Rectification of debatable deduction claims cannot reverse scrutiny-approved co-operative society interest income deductions as apparent record errors...
Cash-method accounting bars presumptive interest taxation, while unsupported securities and share-trading additions require reliable material and veri...
A credit co-operative society's interest income from deposits and investments with nationalised banks was held eligible for deduction under section 80P(2)(a)(i) because the funds were placed in the course of business to maintain liquidity and meet operational requirements. The ITAT applied co-ordinate Bench rulings on the same issue, found the principle squarely applicable on the facts, and noted that no binding contrary precedent was shown by the Revenue. The interest was treated as attributable to the assessee's business of providing credit facilities to members, so the disallowance was unsustainable and the deduction was allowed for the assessment years under appeal.
A credit co-operative society's interest income from deposits and investments with nationalised banks was held eligible for deduction under section 80P(2)(a)(i) because the funds were placed in the course of business to maintain liquidity and meet operational requirements. The ITAT applied co-ordinate Bench rulings on the same issue, found the principle squarely applicable on the facts, and noted that no binding contrary precedent was shown by the Revenue. The interest was treated as attributable to the assessee's business of providing credit facilities to members, so the disallowance was unsustainable and the deduction was allowed for the assessment years under appeal.
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