Restriction of Input Tax Credit under Rule 86A applies only to fraudulently or ineligible availed credit; mere wrongful recipient availment is insuffi...
Business reorganisation requires recognition of successor's modified return; draft orders against dissolved transferor quashed and fresh review direct...
Pre-commencement R&D deduction denied where business had not commenced; deeming benefit requires tangible start of manufacture or commercial exploitat...
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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