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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Relief under the salary-arrear relief provision was considered in relation to exemptions for voluntary retirement payments; the tribunal accepted that gratuity, leave encashment, voluntary retirement compensation and arrears may be exempt and that relief under the arrears-relief provision can be claimed in addition to the statutory exemption. Relying on cited precedents, the tribunal remitted the common computation issue to the assessing officer for verification and recalculation of the arrears relief in accordance with law, directing reasonable opportunity to the assessee and allowing the appeals for statistical purposes.
Relief under the salary-arrear relief provision was considered in relation to exemptions for voluntary retirement payments; the tribunal accepted that gratuity, leave encashment, voluntary retirement compensation and arrears may be exempt and that relief under the arrears-relief provision can be claimed in addition to the statutory exemption. Relying on cited precedents, the tribunal remitted the common computation issue to the assessing officer for verification and recalculation of the arrears relief in accordance with law, directing reasonable opportunity to the assessee and allowing the appeals for statistical purposes.
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