Deduction of interest income from co-operative banks under section 80P(2)(d) HELD THAT: - Following Maviyali Service Cooperative Bank Ltd. [2021 (1) TMI 488 - SUPREME COURT] Tribunal accepted the appellant's entitlement to the claimed deduction. [Paras 7, 8] The interest income was held eligible for deduction under section 80P(2)(d). Final Conclusion: The appeal was allowed and the deduction claimed under section 80P(2)(d) on interest received from co-operative banks was held allowa... ... ...

Revisionary jurisdiction - Capital-gains exemption u/s 54B - date of transfer under agreement to sell - investment from advance sale consideration Validity of revision of an assessment allowing deduction under section 54B for agricultural land purchased after receipt of advance sale consideration but before execution of the sale deed - HELD THAT: - For capital-gains exemption, the date of transfer is reckoned from the agreement to sell where substantial rights have been transferred and posses... ... ...

Interest on unsecured loans from directors - Business purpose of borrowings - Allowability of interest on unsecured loans obtained from directors for business purposes HELD THAT: - The interest claim was governed by the specific provision for interest on borrowings and could be disallowed only upon a finding that the borrowings were not used for the assessee's business. As no finding of diversion for non-business purposes was recorded, invocation of the general provision relating to in... ... ...

Unexplained money - cash deposits in specified bank notes from recorded business receipts - Specified Bank Notes - acceptance before appointed date Cash deposits in specified bank notes - explained business receipts - Unexplained money - unrejected books of account - Addition as unexplained money for cash deposits in specified bank notes during demonetisation despite their explanation as recorded sales and trade-debtor collections - HELD THAT: - The cash deposits were supported by the books o... ... ...

Cash realisations from accepted opening debtor balances - Addition for cash realised from money-lending debtors despite accepted opening debtor balances HELD THAT: - The Revenue had accepted the assessee's money-lending business, the outstanding debtor balances and the interest income from that business in the preceding scrutiny assessment. In the absence of material to doubt the genuineness of those opening balances, or to establish that the money-lending business was not genuine, realis... ... ...

Unexplained investments u/s 69 - recorded and traceable business purchases Addition as unexplained investment in respect of business purchases paid through credit card and recorded through the disclosed bank account - HELD THAT: - Section 69 applies only where an investment is not recorded in the books of account maintained by the assessee. The business purchases were undisputed, recorded and traceable through banking channels; consequently, mere dissatisfaction regarding the source of a part... ... ...

Deduction for provision for bad and doubtful debts - Bad-debt write-off of non-rural advances - Disallowance of expenditure relating to exempt income from bank investments - Provision for employee wage arrears - Valuation of bank investment securities - Deductibility of RBI monetary penalty for KYC-AML non-compliance Deduction for provision for bad and doubtful debts - Provision for NPA - Deduction for a bank's provision described in its accounts as 'provision for NPA' under secti... ... ...

Cash deposits representing sale consideration - Disallowance of cost of improvement of capital assets Cash deposits representing sale consideration - Addition for cash deposits following sale of capital assets where the source was not fully reconciled - HELD THAT: - The sale of the capital assets supported an inference that the deposits represented the cash component of the sale consideration. However, as the assessee had not satisfactorily reconciled all relevant figures to explain their sou... ... ...

Section 14A disallowance limited to exempt income - Ceiling of exempt income - permissible extent of disallowance under section 14A read with Rule 8D where exempt income was earned HELD THAT: - The Tribunal applied the settled legal position in STATE BANK OF PATIALA [2018 (11) TMI 1565 - SC ORDER] disallowance under section 14A read with Rule 8D cannot exceed the exempt income earned by the assessee. The computation under Rule 8D must therefore remain confined to that income. [Paras 7] The... ... ...

Slump sale of business undertaking - Agency-termination compensation under principal-to-principal licence - Capital receipt on extinction of income source Slump sale of business undertaking - Taxability of slump sale before section 50B - Characterisation of the transfer of the entire bottling and marketing undertaking as a slump sale and applicability of the capital-gains regime governing such transfers for Assessment Year 1998-99 - HELD THAT: - The concurrent findings established that the en... ... ...

Denial of charitable exemption for contravention of section 13(1)(d) - Forfeiture of charitable exemption for contravention of investment conditions - Maximum marginal rate on income forfeiting exemption - scope of income taxable at the maximum marginal rate HELD THAT: - The parties agreed that the controversy stood governed by an earlier decision of the Court. Concurring with that decision WORKING WOMEN'S FORUM [2014 (8) TMI 681 - MADRAS HIGH COURT], the Court held that forfeiture of exe... ... ...

GST input tax credit is the subject of a request for case law on whether the tax-payment condition under section 16(2)(c) may be applied mechanically to deny credit. Although purported departmental guidelines are mentioned, no decision, guideline content, factual context, or operative legal standard is supplied.

Regional Rural Banks are deemed to be co-operative societies for income-tax purposes under the Regional Rural Banks Act, with its overriding provision supporting consideration of deduction for banking income despite the exclusion applicable to certain co-operative banks. Eligibility for the deduction depends on verification of the bank's factual position, including its prior tax treatment and supporting financial material. Interest payable for default in deducting tax at source is tax-related in character rather than an allowable business expense and is therefore not deductible.

Recognition of foreign certifying authorities requires Controller approval, a local office in India, audited infrastructure meeting equivalent Indian standards, financial assurance, and a compliance agreement. Recognized entities must maintain equivalent information-security controls, conduct annual external and half-yearly internal audits, submit audit reports, and bear inspection costs. Recognition lasts five years and is non-transferable. Such entities cannot issue Digital Signature Certificates to Indian nationals residing in India, and certificates issued before recognition are invalid for statutory purposes. Suspension, revocation, renewal, refusal and cessation are governed by specified compliance, disclosure, notice and record-preservation obligations.

Foreign certifying authorities may be recognised where they are authorised by an overseas regulatory authority whose legal reliability standards are at least equivalent and reciprocal. Recognition is non-transferable, does not validate certificates issued before recognition, and may be suspended or revoked when overseas authorisation is suspended or revoked. Recognised foreign certifying authorities cannot issue Digital Signature Certificates to Indian nationals residing in India. Renewal requires timely application, while cessation requires advance notices, subscriber communication, record preservation, disruption-minimisation measures, and reasonable restitution for early certificate revocation.

Central Government rescinds two specified Department of Information Technology notifications issued in 2003 under the Information Technology Act, 2000. The rescission remains subject to a savings provision, preserving things done or omitted before withdrawal and leaving unaffected acts and omissions occurring while the earlier notifications remained operative.

Appointment as Controller of Certifying Authorities requires prescribed technical, scientific or management qualifications combined with substantial experience in information technology or related sectors, including five years at senior management level. The Controller serves for three years, is eligible for reappointment, and cannot hold office beyond 65 years of age. Pay and benefits correspond to those of a Secretary to the Government of India, subject to adjustment for pension and other retirement benefits. The Central Government may relax requirements for specified classes or categories.

A private discretionary trust created under a will proposes remittances of current income to NRI beneficiaries under the Liberalised Remittance Scheme. The bank has indicated TCS at 20% on qualifying remittances, while the trust's effective tax liability is estimated to be lower. The issue is whether nil or reduced TCS may be obtained, or whether collection may be limited to the trust's effective tax liability.

Information Technology (Security Procedure) Amendment Rules, 2015 amend the Security Procedure Rules, 2004 by aligning undefined terms with meanings under the Information Technology Act, 2000 and the Digital Signature (End entity) Rules, 2015. They also require compliance with prescribed digital-signature standards relating to the creation, storage and transmission of digital signatures.

Secure electronic records are authenticated through secure digital signatures. Secure digital signatures require key-pair generation and private-key retention within a cryptographic smart card or hardware token, with the content hash signed through that device. Control of token or card information must remain solely with the purported signatory, and verification must be possible through the public key in that person's Digital Signature Certificate. Applicable standards for digital-signature creation, storage, and transmission must be met, and any alteration of the electronic record must invalidate the signature.