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...
Exemption u/s 10(10AA) - exemption from income tax from the leave encashment amount at the time of retirement of the employees other than government employees - as argued employees of the Bank as also the Public Sector Undertakings cannot be treated differently holding the equality clause of Article 14 of the Constitution of India - The High Court dismissed the writ petition, affirming the constitutionality of Section 10(10AA) of the Income Tax Act, 1961. It upheld the classification made in the provision, considering the distinct status and privileges enjoyed by government employees compared to employees of other sectors.
Exemption u/s 10(10AA) - exemption from income tax from the leave encashment amount at the time of retirement of the employees other than government employees - as argued employees of the Bank as also the Public Sector Undertakings cannot be treated differently holding the equality clause of Article 14 of the Constitution of India - The High Court dismissed the writ petition, affirming the constitutionality of Section 10(10AA) of the Income Tax Act, 1961. It upheld the classification made in the provision, considering the distinct status and privileges enjoyed by government employees compared to employees of other sectors.
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