Transfer pricing comparability under TNMM: foreign exchange loss on ECB excluded from operating cost, and a functionally dissimilar comparator removed...
Fake AI-generated precedents vitiate adjudication, with unverified citations contaminating the decision-making process and undermining the rule of law...
The note records an ITAT ruling on banking and employee-benefit tax issues. Actuarially valued pension, leave-travel/home-travel, and other long-term employee benefit provisions were treated as ascertained liabilities and allowed, while privilege leave encashment remained deductible only on actual payment. Interest on NPAs and non-performing investments was taxed only on real income, and securities in AFS/HFT/HTM categories were accepted at lower of cost or market value. The Tribunal also held that MAT does not apply to corresponding new banks, upheld business-expediency deductions for staff welfare and retired employees' medical benefits, and remitted or rejected several claims for lack of verification or supporting material.
The note records an ITAT ruling on banking and employee-benefit tax issues. Actuarially valued pension, leave-travel/home-travel, and other long-term employee benefit provisions were treated as ascertained liabilities and allowed, while privilege leave encashment remained deductible only on actual payment. Interest on NPAs and non-performing investments was taxed only on real income, and securities in AFS/HFT/HTM categories were accepted at lower of cost or market value. The Tribunal also held that MAT does not apply to corresponding new banks, upheld business-expediency deductions for staff welfare and retired employees' medical benefits, and remitted or rejected several claims for lack of verification or supporting material.
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