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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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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