Transfer pricing comparability: one support-services company accepted, government-owned and facility-management comparables excluded, forex loss claim...
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Interest received on enhanced compensation was held taxable under the head "Income from Other Sources" after the post-2009 statutory scheme, with only the prescribed 50% deduction available; the claim for exemption under section 10(37) was rejected. The Tribunal followed its earlier coordinate-bench ruling and treated the amended provisions as governing the tax treatment of interest on compensation. The assessee's challenge to the reassessment, based on non-supply of recorded reasons and absence of a transfer intimation under the faceless procedure, also failed because participation in the proceedings showed no demonstrated prejudice and no incurable jurisdictional defect was established. The assessment was upheld and the appeal was dismissed.
Interest received on enhanced compensation was held taxable under the head "Income from Other Sources" after the post-2009 statutory scheme, with only the prescribed 50% deduction available; the claim for exemption under section 10(37) was rejected. The Tribunal followed its earlier coordinate-bench ruling and treated the amended provisions as governing the tax treatment of interest on compensation. The assessee's challenge to the reassessment, based on non-supply of recorded reasons and absence of a transfer intimation under the faceless procedure, also failed because participation in the proceedings showed no demonstrated prejudice and no incurable jurisdictional defect was established. The assessment was upheld and the appeal was dismissed.
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