Donor-directed corpus contributions retain capital character despite exemption claims under section 10(23C)(vi), preventing their treatment as taxable...
Enhanced tax-audit threshold applies where banking records establish compliant non-cash receipts and payments, eliminating penalty exposure for audit ...
Transfer pricing consistency protects identical non-interest-bearing debenture terms from a later notional-interest adjustment without valid statutory...
Rectification of debatable deduction claims cannot reverse scrutiny-approved co-operative society interest income deductions as apparent record errors...
Cash-method accounting bars presumptive interest taxation, while unsupported securities and share-trading additions require reliable material and veri...
The Tribunal held that the enhanced leave-encashment exemption ceiling of Rs. 25 lakhs under section 10(10AA)(ii), introduced by CBDT Notification No. 31/2023, was beneficial and remedial in nature and therefore applied to pending matters for assessment year 2020-21. It reasoned that the notification did not create a new exemption but removed a disparity between government and non-government employees, and that denying the higher ceiling to persons retiring before the notification would create an artificial distinction contrary to the amendment's object. The restriction of exemption to Rs. 3 lakhs was held unsustainable, and the leave encashment received within the enhanced ceiling was allowed as exempt.
The Tribunal held that the enhanced leave-encashment exemption ceiling of Rs. 25 lakhs under section 10(10AA)(ii), introduced by CBDT Notification No. 31/2023, was beneficial and remedial in nature and therefore applied to pending matters for assessment year 2020-21. It reasoned that the notification did not create a new exemption but removed a disparity between government and non-government employees, and that denying the higher ceiling to persons retiring before the notification would create an artificial distinction contrary to the amendment's object. The restriction of exemption to Rs. 3 lakhs was held unsustainable, and the leave encashment received within the enhanced ceiling was allowed as exempt.
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