Pre-amendment reassessment limitation bars late notices under the preserved regime, invalidating consequential reassessment for affected earlier asses...
Cash-sales explanations for bank deposits require documentary reconciliation; reassessment notice survived where effective response time was available...
Functional comparability in transfer pricing prevents ad hoc arm's length adjustments where functions, assets, risks and reliable comparables are unes...
Contingency expenses, exempt-income disallowance, and royalty benchmarking: unsupported adjustments were deleted under consistent accounting and trans...
ITAT affirmed that section 10(10AA)(i) is confined to employees of the Central or State Government and does not extend to statutory corporations or government-owned companies; being owned or governed by State service rules does not render the employer a "State Government." The assessee, a retired PSU employee, falls within clause (ii) and is therefore eligible only for the capped exemption of Rs. 3,00,000 for leave encashment on superannuation. The Tribunal applied its coordinate bench precedent and dismissed the assessee's appeal, holding that any claim for exemption beyond Rs. 3,00,000 is not tenable under section 10(10AA).
ITAT affirmed that section 10(10AA)(i) is confined to employees of the Central or State Government and does not extend to statutory corporations or government-owned companies; being owned or governed by State service rules does not render the employer a "State Government." The assessee, a retired PSU employee, falls within clause (ii) and is therefore eligible only for the capped exemption of Rs. 3,00,000 for leave encashment on superannuation. The Tribunal applied its coordinate bench precedent and dismissed the assessee's appeal, holding that any claim for exemption beyond Rs. 3,00,000 is not tenable under section 10(10AA).
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