Approved resolution plans extinguish unsubmitted pre-approval tax claims, preventing later recovery outside the insolvency process and preserving a cl...
Transfer pricing comparability requires functional alignment and permits working capital adjustment, while APA margins cannot govern non-covered years...
Treaty benefit, goodwill depreciation and hedging costs: export commission disallowed, while key business deductions and depreciation claims succeeded...
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.
Note: It is a system-generated summary and is for quick reference only.