S.92C: Transfer pricing -Arm’s length price – Avoidance of tax -International transaction – Specified domestic transaction – Comparables -Gujarat Fluorochemicals Limited -Inox Air Products Limited -Excluded- Purchase and subsequent sale of capital asset- Matter remanded. [S.92CA]
S. 92C : Transfer pricing -Arm’s length price – Avoidance of tax -International transaction – Specified domestic transaction- Comparable-Accentia Technologies Limited, Eclerx Services Limited, and TCS E-Serve Ltd. – Functionally different -Rejection by CIT(A) is upheld. [S.92CA]
S. 90 : Double taxation relief -A resident of Mauritius earning income from the transfer of shares of Indian companies should be subject to capital gains tax exclusively in Mauritius, rather than in India- Appeal of Revenue is dismissed – DTAA -India -Mauritius [Art. 13 (4)]
S. 80P : Co-operative societies -Deductions -Commission income on collection of MSEDCL bills which was from business activity carried on by assessee, same was eligible for deduction under section 80P(2)(a) [S.80P(2)(a)]
S. 80P : Co-operative societies – Grants –Miscellaneous income cannot be assessed as income from other sources – Eligible for deduction. [S. 56]
S. 80P : Co-operative societies -Interest -Co -Operative Banks and Nationalised Banks – Eligible for deduction.[S.80P(2)]
S.80P: Co-operative societies -Interest – Surplus funds -Co -Operative banks and Schedule banks -Eligible deduction. [S.80P(2)(a)(i), 80P(2)(d)]
S. 80IC: Special category States –Return filed within due date –Audit report -Form No.10CCBB is filed along with original return – Denial of exemption is not valid. [S.92E, 139(1), 143(1), Form No 3CEB, 10CCB]
S.80GGA: Donation -Scientific Research -Rural development -At the time of making of donation the charitable trust was duly approved under section 35AC -Subsequent withdrawal -Denial of deduction is held to be not valid.[S.35AC(2), 80GGA(2) (bb), 147, 148]
80G: Donation – Denial of final approval -Due to technical reason -Mentioning of wrong clause Rectifiable mistake. [S. 12A, 80G (5)(vi)]