Patent-settlement expenditure treated as commercially expedient revenue outlay, with foreign-law restrictions inapplicable before the prospective amen...
International transaction benchmarking restricts transfer pricing adjustments to associated-enterprise dealings, while functional comparability govern...
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Section 10(26) exemption for a Scheduled Tribe assessee is not automatic; it applies only when the statutory conditions coexist, including that the salary income accrues or arises from a source situated in the notified area. Salary generally accrues where the services are performed, so the employer's office location is not decisive. On the record produced, the employer's certificate only showed current work-from-home status and did not establish that the assessee worked from Meghalaya for the full relevant year, while the employment terms were not produced. The Tribunal therefore remanded the exemption claim to the Assessing Officer for fresh consideration.
Section 10(26) exemption for a Scheduled Tribe assessee is not automatic; it applies only when the statutory conditions coexist, including that the salary income accrues or arises from a source situated in the notified area. Salary generally accrues where the services are performed, so the employer's office location is not decisive. On the record produced, the employer's certificate only showed current work-from-home status and did not establish that the assessee worked from Meghalaya for the full relevant year, while the employment terms were not produced. The Tribunal therefore remanded the exemption claim to the Assessing Officer for fresh consideration.
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