The assessee is, admittedly, neither a `primary agricultural credit society’ nor a `primary cooperative agricultural and rural development bank’. As such, it is not covered by the exceptions to s. 80P(4), as provided by the said sub-section itself, denying deduction u/s. 80P to all cooperative banks. The Legislature in its wisdom restricted the exemption, which extends to the whole of the specified incomes, i.e., of cooperatives societies undertaking specified activities, w.e.f. 1/4/2007 to the said two primary units, where the assessee is a cooperative bank. The assessee in the instant case being an apex cooperative society lending money to such primary units functioning within the State of Kerala, he denied the assessee its claim for deduction u/s. 80P (2)(a)(i).
The assessee is not entitled to adjustment of 5 per cent as stipulated u/s 92C(2), where only one of the several methods specified u/s 92C(1) is applied by the assessee to determine the arm’s length price
Whether salary credited to a bank account in India for services rendered there by a non-resident was taxable in India?
This decision is relevant to assessees following RBI guidelines for accounting for interest rates swaps. Companies which are claiming unrealised loss on outstanding interest rate swaps at the year end would find this ruling useful. While this ruling
The Chennai Tribunal has held that payments towards IPLC / dedicated bandwidth are towards use of ‘equipment’ or ‘process’ and therefore would qualify as royalty under the Act as well as DTAA. It may be noted that the proposition on ‘process’ eleme
In principle, the CUP method (the traditional transaction method) is preferable to the other methods because all other things being equal, the CUP and traditional transactional methods lead to more reliable results vis-a-vis the results obtained by a
The learned CIT has also given one more reason that it is not comprehensible as to why not the assessee got itself registered as a society,if the motive of the assessee was to do activities of public charity. This reason given by the CIT is found, in
Pyramid Infrastructure Pvt. Ltd. Vs DCIT (ITAT Hyderabad) – The issues taken up by the CIT for revision of assessment under section 263 of the Act, namely, work-in-progress & closing stock, opening stock, and dis-allowance of expenditure on account of various heads, have already been considered by the assessing officer in the assessment proceedings under section 143(3) of the Act.
The Tribunal held that income earned by the taxpayer on sale of factory building, plant and machinery although not taxable as “Profit and gains of business or profession” was in the nature of income of business though assessed as capital gains and h
The argument that “controlling interest” was transferred with the shares was not acceptable as the share purchase agreement had been signed by the Power of Attorney (“POA”) holder. In the absence of the copy of the same, which would determine whether
