Transfer pricing requires evidence for AMP transactions, functionally reliable comparables, and appropriate aggregation or Berry Ratio benchmarking me...
Revisionary jurisdiction cannot reopen share capital assessments where adequate inquiry supports a permissible view and no independent error is establ...
Reassessment jurisdiction fails where unverified portal information is aggregated without examining the taxpayer's explanation or relevance of entries...
Statutory sanction for delayed reassessment requires approval from the prescribed authority; approval by an inferior authority invalidates jurisdictio...
Transfer pricing margin adjustments require matching treatment of non-operating income and related costs, with comparability issues reconsidered on ev...
Preliminary-expense amortisation and MAT exempt-income adjustments prevailed, while trademark costs and managerial remuneration require fresh verifica...
Export valuation requires contemporaneous evidence; unrelated invoices cannot prove overvaluation, and dual penalties on firm and partner are impermis...
Compensation paid to BSNL employees under the BSNL Voluntary Retirement Scheme, 2019 was treated as retrenchment compensation because the payment arose from a forced workforce reduction under the Government-approved revival plan. Applying its earlier ruling on the same scheme, the ITAT held that the receipt fell under section 10(10B), not section 10(10C), and was a capital receipt exempt from tax. The assessees were therefore entitled to exemption, with directions to file revised computations before the jurisdictional Assessing Officers for consequential verification and refund, if due.
Compensation paid to BSNL employees under the BSNL Voluntary Retirement Scheme, 2019 was treated as retrenchment compensation because the payment arose from a forced workforce reduction under the Government-approved revival plan. Applying its earlier ruling on the same scheme, the ITAT held that the receipt fell under section 10(10B), not section 10(10C), and was a capital receipt exempt from tax. The assessees were therefore entitled to exemption, with directions to file revised computations before the jurisdictional Assessing Officers for consequential verification and refund, if due.
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