Transfer pricing comparability requires functional alignment, reliable financial data, and careful review of working capital and receivables adjustmen...
Transfer pricing rules require benchmarking corporate guarantees and associated-enterprise advances, while invalid domestic-transaction adjustments ca...
Prospective sugar export prohibition required registered letters of credit; private contracts and export quotas created no enforceable continuation ri...
Retroactive interim-moratorium exclusion permits protective asset disclosure and preservation measures against personal guarantors pending arbitration...
Payment received under an employer's ERS/VRS scheme, being ex gratia compensation on cessation of employment and not shown to arise from any enforceable obligation for termination, was held not taxable as profits in lieu of salary under section 17(3)(i). Following its earlier decision on similar facts, the Tribunal found no contrary material from the Revenue and held that the addition sustained by the appellate authority was unsustainable. The addition was directed to be deleted.
Payment received under an employer's ERS/VRS scheme, being ex gratia compensation on cessation of employment and not shown to arise from any enforceable obligation for termination, was held not taxable as profits in lieu of salary under section 17(3)(i). Following its earlier decision on similar facts, the Tribunal found no contrary material from the Revenue and held that the addition sustained by the appellate authority was unsustainable. The addition was directed to be deleted.
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