Gross-profit additions on disputed purchases require reasoned appellate determination; disclosed claims alone do not support inaccurate-particulars pe...
Limitation after transfer-pricing remand: fresh TPO reference did not extend the assessment deadline, rendering the consequential assessment time-barr...
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Regional Rural Banks are deemed to be co-operative societies for Income-tax Act purposes under the statutory fiction in section 22 of the Regional Rural Banks Act. That fiction remains effective because section 80P(4) does not displace it, and definitions of primary co-operative bank or primary credit society are inapplicable where the bank is not claimed to fall within those categories. Deduction under section 80P is therefore available. An assessment correctly granting that deduction is not erroneous and prejudicial to the interests of the Revenue, limiting revision under section 263.
Regional Rural Banks are deemed to be co-operative societies for Income-tax Act purposes under the statutory fiction in section 22 of the Regional Rural Banks Act. That fiction remains effective because section 80P(4) does not displace it, and definitions of primary co-operative bank or primary credit society are inapplicable where the bank is not claimed to fall within those categories. Deduction under section 80P is therefore available. An assessment correctly granting that deduction is not erroneous and prejudicial to the interests of the Revenue, limiting revision under section 263.
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TaxTMI 
TaxTMI 
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