Transfer pricing comparability under TNMM: foreign exchange loss on ECB excluded from operating cost, and a functionally dissimilar comparator removed...
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Arrears of the employer's contribution to an approved superannuation fund, though taxable as a perquisite, formed part of salary for relief on income received in arrears. The Tribunal held that relief for salary received in arrears extends to arrears of perquisites included in salary, and that Rule 21A and Form 10E apply to such claims under Rule 21A(1)(a) read with Rule 21A(2), not the residuary provision. An internal circular treating the amount as a perquisite could not override the Act. The assessee was therefore entitled to relief and the claim had to be allowed.
Arrears of the employer's contribution to an approved superannuation fund, though taxable as a perquisite, formed part of salary for relief on income received in arrears. The Tribunal held that relief for salary received in arrears extends to arrears of perquisites included in salary, and that Rule 21A and Form 10E apply to such claims under Rule 21A(1)(a) read with Rule 21A(2), not the residuary provision. An internal circular treating the amount as a perquisite could not override the Act. The assessee was therefore entitled to relief and the claim had to be allowed.
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