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...
ITAT held that the addition under s.17(2)(v) for AY 2018-19 is unsustainable: employer's contribution to LIC for an annuity, not credited to or paid on behalf of the assessee and not creating any vested or enforceable right in the relevant year, cannot be taxed as a perquisite. Taxing the contribution in AY 2018-19 would result in impermissible double taxation because the assessee has already offered annuity receipts to tax on accrual/receipt as salary. Reliance on Form 16/26AS does not override substantive statutory provisions. Consequently, the AO's addition is deleted and the appeal is allowed in favour of the assessee.
ITAT held that the addition under s.17(2)(v) for AY 2018-19 is unsustainable: employer's contribution to LIC for an annuity, not credited to or paid on behalf of the assessee and not creating any vested or enforceable right in the relevant year, cannot be taxed as a perquisite. Taxing the contribution in AY 2018-19 would result in impermissible double taxation because the assessee has already offered annuity receipts to tax on accrual/receipt as salary. Reliance on Form 16/26AS does not override substantive statutory provisions. Consequently, the AO's addition is deleted and the appeal is allowed in favour of the assessee.
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