Development agreements require legal possession or effective enjoyment for capital gains transfer; permissive possession and deferred consideration de...
Prolonged sterilisation of development rights supports capital-gains treatment, while business-income disallowances cannot govern capital-gains comput...
Additional evidence in transfer pricing dispute leads to fresh examination, while tax deductions, TDS credit, fee and refund interest require verifica...
Category II AIF pass-through taxation preserves non-business income character; investment receipts cannot be reclassified without applying recognised ...
Mutual fund maturity rules require proper rollover, redemption, disclosure, and due diligence; investor gains cannot excuse regulatory breaches or pen...
Threshold exemption excludes exempt services, while stamp-paper purchases avoid reverse charge; consequential service tax penalties were also set asid...
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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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