“Section 57(4)”

Disallowance under Section 14A applies only when exempt income is actually received or receivable during the relevant previous year. The provision does not trigger merely upon incurring expenditure if no exempt income materialized in that year.

Section 80P(4) is not applicable to a cooperative bank unless it is classified as a 'bank' under the provisions of the Banking Regulation Act, 1949. For cooperative banks not meeting this definition, the deduction for interest earned from investments in cooperative societies is available under Section 80P(2)(d) of the Income-tax Act.

Interest income earned by a co-operative bank from statutory investments or mandatory deposits, which are essential for conducting its banking business, qualifies as business income and is exempt under Section 80P(2)(a)(i) of the Income-tax Act.

If the Revenue accepts the Tribunal's decision for earlier years without challenge, it cannot assail the same decision in subsequent years, provided the facts are similar.

Expenditure incurred for the purpose of earning income is deductible under Section 57(iii) even if no income is actually earned. The earning of income is not a pre-condition for allowing the deduction.

Statements made under Section 132(4) of the Income-tax Act, 1961, during a search and seizure operation can be retracted, but such retractions must be substantiated.

To determine the predominant object of an entity for tax exemption purposes, the objects of the society should be examined, not merely the quantum of surplus generated. The quantum of surplus may become relevant in certain circumstances.