Revenue neutrality in domestic related-party loans can require deletion of interest transfer pricing adjustments after domestic-transaction verificati...
Pre-enactment land-sale agreements escape stamp-duty value substitution where substantial banking-channel consideration was received before Section 43...
Customs valuation and classification require comparable evidence and assessment of imported goods in their actual condition, invalidating related pena...
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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