Transfer pricing comparables and operating income principles applied to software development services, with exclusions, inclusions, and tax credit ver...
Transfer pricing on performance guarantees and overdue receivables deleted where warranty obligations were embedded and working capital adjustment alr...
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.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
of 4805
Join Channel
TaxTMI 
