Transfer pricing comparability under TNMM: foreign exchange loss on ECB excluded from operating cost, and a functionally dissimilar comparator removed...
Fake AI-generated precedents vitiate adjudication, with unverified citations contaminating the decision-making process and undermining the rule of law...
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.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4817 
Join Channel 
