Reopening of assessment cannot rest solely on an audit party's opinion; reassessment under Section 147/148 is impermissible and power of revision shou...
Tested party selection: functional analysis identified the least complex unit as the appropriate tested party, altering the transfer pricing adjustmen...
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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