TNMM functional comparability requires excluding rice manufacturers from a pure Basmati rice trader's benchmark and recognising operating export recei...
Working-capital adjustment subsumes delayed-receivable effects in TNMM benchmarking of captive software-development services, avoiding separate notion...
Transfer-pricing comparability requires exclusion of financially illogical super-profit comparables and correction of unsupported annual-report and ma...
Charitable character assessment preserves Section 80G approval despite inclusive spiritual teachings and incidental religious expenditure within the s...
Penalty proceedings for cash-loan acceptance require assessment proceedings and recorded Assessing Officer satisfaction; absent these, the proceedings...
Functional comparability governs software-service benchmarking: dissimilar companies are excluded, while related-party filters, margins and working-ca...
Enhanced exemption for leave encashment under section 10(10AA)(ii), notified with effect from 1 April 2023, is claimed by retired employees who superannuated before the notification came into force. Since the petitions were filed before expiry of the period for filing revised returns, the employees may pursue revised returns and other remedies available under the Act. Eligibility for the enhanced exemption, including its application to pre-notification superannuation, remains open for consideration in those proceedings.
Enhanced exemption for leave encashment under section 10(10AA)(ii), notified with effect from 1 April 2023, is claimed by retired employees who superannuated before the notification came into force. Since the petitions were filed before expiry of the period for filing revised returns, the employees may pursue revised returns and other remedies available under the Act. Eligibility for the enhanced exemption, including its application to pre-notification superannuation, remains open for consideration in those proceedings.
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