Transfer-pricing treatment of ITeS margins excludes pass-through tax recoveries and separate delayed-receivables interest after working-capital adjust...
Capacity-utilisation adjustments under TNMM can neutralise substantiated COVID-related idle costs where underutilisation materially affects profitabil...
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...
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ITAT held that employees of the State Power Corporation are not "Government employees" or employees of a qualifying Government undertaking for purposes of s.10(10AA)/10(10A) IT Act. Accordingly, exemption on leave encashment is not available for the period of service rendered under the Corporation. However, ITAT found that the predecessor State Electricity Board constituted an undertaking of the State Government falling within s.10(10AA)/10(10A). Since A1 had rendered qualifying service with the Board from 18.11.1983 to 16.04.2010 and was subsequently compulsorily transferred to the Corporation under a restructuring scheme, denial of exemption for the portion relatable to Board service would defeat the beneficial object of the provision. ITAT therefore upheld relief for leave encashment of Rs.13,02,816 relatable to the Board service, while confirming taxability of the balance relatable to service with the Corporation.
ITAT held that employees of the State Power Corporation are not "Government employees" or employees of a qualifying Government undertaking for purposes of s.10(10AA)/10(10A) IT Act. Accordingly, exemption on leave encashment is not available for the period of service rendered under the Corporation. However, ITAT found that the predecessor State Electricity Board constituted an undertaking of the State Government falling within s.10(10AA)/10(10A). Since A1 had rendered qualifying service with the Board from 18.11.1983 to 16.04.2010 and was subsequently compulsorily transferred to the Corporation under a restructuring scheme, denial of exemption for the portion relatable to Board service would defeat the beneficial object of the provision. ITAT therefore upheld relief for leave encashment of Rs.13,02,816 relatable to the Board service, while confirming taxability of the balance relatable to service with the Corporation.
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