Transfer pricing comparability under TNMM: foreign exchange loss on ECB excluded from operating cost, and a functionally dissimilar comparator removed...
Fake AI-generated precedents vitiate adjudication, with unverified citations contaminating the decision-making process and undermining the rule of law...
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Profits in lieu of salary u/s 17(3)(i) - payment received by the assessee as lump sum amount after his termination from service and sum received for the purchase of new car - The Tribunal noted the argument of the assessee that these payments were voluntary and not conditioned by any legal duty or obligation. Relying on legal precedents, including a decision from the Delhi High Court, the Tribunal concluded that voluntary payments made by the employer, not arising from a legal duty, are not to be treated as profits in lieu of salary under Section 17(3)(i). Therefore, the Tribunal upheld the decision of the CIT(A) to delete the addition of these amounts to the assessee's income.
Profits in lieu of salary u/s 17(3)(i) - payment received by the assessee as lump sum amount after his termination from service and sum received for the purchase of new car - The Tribunal noted the argument of the assessee that these payments were voluntary and not conditioned by any legal duty or obligation. Relying on legal precedents, including a decision from the Delhi High Court, the Tribunal concluded that voluntary payments made by the employer, not arising from a legal duty, are not to be treated as profits in lieu of salary under Section 17(3)(i). Therefore, the Tribunal upheld the decision of the CIT(A) to delete the addition of these amounts to the assessee's income.
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