Transfer pricing comparables and adjustments: Tribunal revisits loss-maker status, segmental comparability, working capital relief, and risk allocatio...
Business expenditure disallowance failed where commission, related-party salary and promotion payments were supported by records and inquiry was inade...
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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