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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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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