Marketing support and subcontracted client contracts: no agency permanent establishment under Article 5 DTAA; arm's-length pricing bars profit attribu...
Transfer pricing comparables selection and working capital adjustment u/r 10B(1)(e)(iii), remanded for recomputation with rejected comparables include...
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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