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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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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