Transfer-pricing comparability permits fresh objections and filters where software service comparables are functionally unsuitable for arm's-length pr...
Territorial rendering requirement excludes China-based management and consultancy services from fees for technical services under the India-China DTAA...
FEMA borrowing restrictions bind charitable trusts, and civil penalties apply without proving intent for delayed repayment of non-resident rupee loans...
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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