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...
The dominant issue was whether leave encashment received by the assessee qualified for full exemption under s.10(10AA) by treating the assessee as a Central Government employee, or whether the exemption was capped at ₹3,00,000. Relying on a prior co-ordinate bench decision holding that employees of such institutions are not Central Government servants for s.10(10AA), the Tribunal upheld the restriction of exemption and rejected the claim for higher relief; the assessee's appeal was dismissed. - ITAT
The dominant issue was whether leave encashment received by the assessee qualified for full exemption under s.10(10AA) by treating the assessee as a Central Government employee, or whether the exemption was capped at ₹3,00,000. Relying on a prior co-ordinate bench decision holding that employees of such institutions are not Central Government servants for s.10(10AA), the Tribunal upheld the restriction of exemption and rejected the claim for higher relief; the assessee's appeal was dismissed. - ITAT
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