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    <title>2018 (4) TMI 553 - ITAT VISAKHAPATNAM</title>
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    <description>Reassessment notices under sections 147 and 148 were upheld because survey material showed a prima facie incorrect gratuity deduction claim and tangible material supported belief of escapement within four years. Contributions paid directly to LIC under an irrevocable group gratuity arrangement were allowed as deduction despite the gratuity fund not yet being approved, as the assessee had no dominion over the funds and the payment was for employees&#039; exclusive benefit. Interest on non-performing assets was held taxable only on receipt basis for a co-operative bank, applying RBI prudential norms and the real income principle. Disallowance for TDS default on advertisement and professional payments was sustained, while surcharge on fringe benefit tax was deleted for a co-operative society.</description>
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      <description>Reassessment notices under sections 147 and 148 were upheld because survey material showed a prima facie incorrect gratuity deduction claim and tangible material supported belief of escapement within four years. Contributions paid directly to LIC under an irrevocable group gratuity arrangement were allowed as deduction despite the gratuity fund not yet being approved, as the assessee had no dominion over the funds and the payment was for employees&#039; exclusive benefit. Interest on non-performing assets was held taxable only on receipt basis for a co-operative bank, applying RBI prudential norms and the real income principle. Disallowance for TDS default on advertisement and professional payments was sustained, while surcharge on fringe benefit tax was deleted for a co-operative society.</description>
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