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Exclusion of limitation period: pandemic suspension plus debtor acknowledgement can extend limitation, requiring fresh factfinding on guarantee invoca...
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Leave encashment exemption under section 10(10AA)(ii) was held to remain capped at Rs. 3 lakh for the year under consideration, because the enhanced limit notified later operated only prospectively from 01.04.2023. The ITAT accepted that the limit should have been revised earlier, but followed the Kerala High Court in Ramesan P. A. and held that retrospective revision could not be directed since issuance of the notification was a matter of executive policy. The Delhi High Court notice order relied on by the assessee in Kamal Kumar Kalia was not treated as binding. The appeal was dismissed and the section 143(1) adjustment sustained.
Leave encashment exemption under section 10(10AA)(ii) was held to remain capped at Rs. 3 lakh for the year under consideration, because the enhanced limit notified later operated only prospectively from 01.04.2023. The ITAT accepted that the limit should have been revised earlier, but followed the Kerala High Court in Ramesan P. A. and held that retrospective revision could not be directed since issuance of the notification was a matter of executive policy. The Delhi High Court notice order relied on by the assessee in Kamal Kumar Kalia was not treated as binding. The appeal was dismissed and the section 143(1) adjustment sustained.
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