The Tribunal held that interest earned from deposits with co-operative banks qualifies for deduction under section 80P. Such interest does not lose its character as business income of an eligible co-operative society.
The issue was whether revision under Section 263 was valid when the AO allowed Section 80P deduction after enquiry. The tribunal held that a plausible and correct view cannot be revised.
ITAT Bangalore held that claiming of amortised upfront fees i.e. 1/5th of the upfront fees paid is not allowable since the entire amount is already claimed as deduction. Accordingly, ground raised by revenue/department is allowed.
The Tribunal held that land cost must be allocated based on saleable/built-up area under the JDA, not total land area. It directed adoption of a higher per-sq-ft land cost while recomputing capital gains.
The Tribunal held that estimating business income at 10% of turnover without citing comparable cases or industry benchmarks is unsustainable. Arbitrary profit estimation must be supported by material evidence.
The Tribunal upheld cancellation after finding that funding practices influenced editorial content and political narratives. The ruling confirms that such conduct constitutes specified violations warranting loss of charitable status.
ITAT Bangalore held that disallowance of entire business losses by Assessing Officer without pointing out specific defects is not permissible. Accordingly, appeal of assessee allowed and order set aside.
The Assessing Officer assumed that no return of income was filed while recording reasons under section 147. The Tribunal ruled that such factually incorrect reasons vitiate the assumption of jurisdiction itself.
The Tribunal held that interest income earned by a co-operative society from deposits with co-operative banks is eligible for deduction under Section 80P(2)(d), subject to verification of amounts.
The Revenue argued AMP functions required separate compensation under DEMPE principles. The Tribunal rejected this, holding that consistent past rulings prevail absent material factual change.
