Marketing support and subcontracted client contracts: no agency permanent establishment under Article 5 DTAA; arm's-length pricing bars profit attribu...
Leave encashment exemption under the income tax provisions was restricted by the assessing officer on the basis that the employer was not a Central or State government; however a subsequent CBDT notification raised the permissible limit. The Tribunal found the AO erred by limiting the exemption to a lower amount and directed grant of the full claimed leave encashment exemption since it falls within the enhanced limit, allowing the assessee's appeal.
Leave encashment exemption under the income tax provisions was restricted by the assessing officer on the basis that the employer was not a Central or State government; however a subsequent CBDT notification raised the permissible limit. The Tribunal found the AO erred by limiting the exemption to a lower amount and directed grant of the full claimed leave encashment exemption since it falls within the enhanced limit, allowing the assessee's appeal.
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