S. 92C : Transfer pricing–Arm’s length price-Comparable-Information Technology enabled services-Companies which are providing knowledge process outsourcing services, medical transcription services, development of infrastructure, high brand value are held to be not comparable. [S. 92CA]
S. 80P : Co-operative societies-Provision for bad debt-Commission expenses-Deductible. [S.80P(2)]
S. 80P : Co-operative societies-Interest from Nationalised Banks-Not entitled to deduction-Net interest from deposits with Scheduled Bank to be excluded from computation of deduction-Interest from Co-Operative Societies or Co-Operative Banks-Entitled to deduction-Net interest to be allowed as deduction. [S.80P(2)(a)(i), 80P(2)(d)]
S. 80P : Co-operative societies-Certificate issued by Registrar of Co-Operative Societies is not binding on AO–Interest on investments with Co-Operative Banks-AO is to follow law laid down by full bench of Kerala High Court in Mavilayi Service Co-Operative Bank Ltd. v. CIT (2019) 414 ITR 67 (FB) (Ker.)(HC) [S.80P(2)(4)]
S. 80G : Donation-Approval-Approval granted to assessee is still continuing-Order rejecting approval is redundant in law. [S. 80G(5)(vi)]
S. 80G : Donation-Corporate Social Responsibility requirements-Denial of approval is not justified. [S. 12A, 80G(5)(vi)]
S. 69A : Unexplained money–Cash gift from brother–Stamp paper used for the alleged gift was purchased after two years after declaration of gift-Addition is held to be valid-regarding professional receipts–Addition is deleted.
S. 69 : Unexplained investments-Books of account not audited–Net profit to be estimated at 8%-Cash gift from relatives-Mother in law-Relative-Agricultural income-No reason to doubt genuineness and creditworthiness of source-Addition is not justified. [S. 56, Explanation, (e), 68]
S. 69 : Unexplained investments-Purchase of property-Source of investment-Remanded to CIT(A). [S. 250]
S. 69 : Unexplained investments–Search and Seizure-Unexplained cash and jewellery-Benefit is given as per circular No 1016 dt 5-11-1994-Explanation is not satisfactory–Addition is held to be justified. [S. 132]