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...
Leave encashment received on retirement by non-government employees under section 10(10AA)(ii) is discussed in relation to a subsequently enhanced exemption ceiling. The enhancement is characterised as a remedial and beneficial measure that rationalises an existing exemption, reduces disparity with government employees, and mitigates hardship. On that approach, the enhanced ceiling is treated as enlarging an existing benefit rather than creating a new exemption, supporting liberal application to pending claims despite no express retrospective provision. Restricting claims to the earlier ceiling could differentiate between similarly placed employees solely by retirement timing.
Leave encashment received on retirement by non-government employees under section 10(10AA)(ii) is discussed in relation to a subsequently enhanced exemption ceiling. The enhancement is characterised as a remedial and beneficial measure that rationalises an existing exemption, reduces disparity with government employees, and mitigates hardship. On that approach, the enhanced ceiling is treated as enlarging an existing benefit rather than creating a new exemption, supporting liberal application to pending claims despite no express retrospective provision. Restricting claims to the earlier ceiling could differentiate between similarly placed employees solely by retirement timing.
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