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...
Assessee received retrenchment compensation under a government approved and funded BSNL Voluntary Retirement Scheme. Tribunal applied the protection in the second proviso to section 10(10B), concluding such severance falls within tax exemption and therefore does not form taxable income; accordingly no tax was exigible or required to be deducted from the package. On identical factual matrix to a coordinate Bench decision, the Tribunal allowed the appeals for the relevant assessment years and held the retrenchment compensation exempt under section 10(10B).
Assessee received retrenchment compensation under a government approved and funded BSNL Voluntary Retirement Scheme. Tribunal applied the protection in the second proviso to section 10(10B), concluding such severance falls within tax exemption and therefore does not form taxable income; accordingly no tax was exigible or required to be deducted from the package. On identical factual matrix to a coordinate Bench decision, the Tribunal allowed the appeals for the relevant assessment years and held the retrenchment compensation exempt under section 10(10B).
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