Transfer pricing requires evidence for AMP transactions, functionally reliable comparables, and appropriate aggregation or Berry Ratio benchmarking me...
Revisionary jurisdiction cannot reopen share capital assessments where adequate inquiry supports a permissible view and no independent error is establ...
Reassessment jurisdiction fails where unverified portal information is aggregated without examining the taxpayer's explanation or relevance of entries...
Statutory sanction for delayed reassessment requires approval from the prescribed authority; approval by an inferior authority invalidates jurisdictio...
Transfer pricing margin adjustments require matching treatment of non-operating income and related costs, with comparability issues reconsidered on ev...
Preliminary-expense amortisation and MAT exempt-income adjustments prevailed, while trademark costs and managerial remuneration require fresh verifica...
Export valuation requires contemporaneous evidence; unrelated invoices cannot prove overvaluation, and dual penalties on firm and partner are impermis...
Enhanced leave-encashment exemption for non-government employees is treated as a beneficial, curative fiscal measure addressing hardship from the previously unrevised limit. Such beneficial provisions receive liberal construction and apply to pending proceedings unless retrospective operation is expressly barred. On that basis, the enhanced ceiling under section 10(10AA) applies to Assessment Year 2021-22, allowing exemption of the full leave-encashment receipt within that ceiling and removing the related addition.
Enhanced leave-encashment exemption for non-government employees is treated as a beneficial, curative fiscal measure addressing hardship from the previously unrevised limit. Such beneficial provisions receive liberal construction and apply to pending proceedings unless retrospective operation is expressly barred. On that basis, the enhanced ceiling under section 10(10AA) applies to Assessment Year 2021-22, allowing exemption of the full leave-encashment receipt within that ceiling and removing the related addition.
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