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...
The ITAT held that the enhanced leave encashment exemption ceiling of Rs. 25 lakhs could not be applied retrospectively to an employee who retired before 01.04.2023. Following the Kerala High Court view in Ramesan P. A. v. Union of India, the Tribunal accepted that extending the benefit to earlier retirees lay within the executive domain and could not be directed by the Court. The assessee's exemption was therefore confined to Rs. 3 lakhs, and the Assessing Officer's consequential addition was sustained.
The ITAT held that the enhanced leave encashment exemption ceiling of Rs. 25 lakhs could not be applied retrospectively to an employee who retired before 01.04.2023. Following the Kerala High Court view in Ramesan P. A. v. Union of India, the Tribunal accepted that extending the benefit to earlier retirees lay within the executive domain and could not be directed by the Court. The assessee's exemption was therefore confined to Rs. 3 lakhs, and the Assessing Officer's consequential addition was sustained.
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