Transfer pricing comparability under TNMM: foreign exchange loss on ECB excluded from operating cost, and a functionally dissimilar comparator removed...
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Retrenchment compensation received by BSNL employees under the 2019 forced retirement scheme was treated as a capital receipt exempt from tax under section 10(10B), not as a limited exemption under section 10(10C), because the payment arose from a retrenchment-style separation scheme linked to the BSNL/MTNL revival plan. The Tribunal also accepted that the assessees could raise the exemption claim in appeal. The contrary view of the CIT(A) was set aside, and the assessees were directed to file revised income computations before the jurisdictional Assessing Officers for verification and consequential refund relief, if any.
Retrenchment compensation received by BSNL employees under the 2019 forced retirement scheme was treated as a capital receipt exempt from tax under section 10(10B), not as a limited exemption under section 10(10C), because the payment arose from a retrenchment-style separation scheme linked to the BSNL/MTNL revival plan. The Tribunal also accepted that the assessees could raise the exemption claim in appeal. The contrary view of the CIT(A) was set aside, and the assessees were directed to file revised income computations before the jurisdictional Assessing Officers for verification and consequential refund relief, if any.
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