Permanent Establishment and Business Connection: foreign consultancy receipts not attributable where no fixed base or corporate veil piercing establis...
Limitation period commencement and procedural inquiry rules: identity-based limitation upheld; complaints by authorised public servants need not attra...
The note addresses tax treatment of compensation paid under the BSNL VRS-2019 scheme, stating that such VRS compensation qualifies for statutory exemption under the applicable VRS exemption provision (subject to relevant rules), and that where the exemption claim was filed before the appellate authority the compensation is not taxable. The operative effect is that the taxpayer is entitled to refund of tax deducted at source on the VRS payment. Procedural details are limited to noting admission of appeals and the appellate determination of exemption and refund entitlement.
The note addresses tax treatment of compensation paid under the BSNL VRS-2019 scheme, stating that such VRS compensation qualifies for statutory exemption under the applicable VRS exemption provision (subject to relevant rules), and that where the exemption claim was filed before the appellate authority the compensation is not taxable. The operative effect is that the taxpayer is entitled to refund of tax deducted at source on the VRS payment. Procedural details are limited to noting admission of appeals and the appellate determination of exemption and refund entitlement.
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