Tax exemption for specified legal-services authority income applies retrospectively, subject to non-commercial activity, unchanged income sources, and...
Approved resolution plans extinguish unsubmitted pre-approval tax claims, preventing later recovery outside the insolvency process and preserving a cl...
Transfer pricing comparability requires functional alignment and permits working capital adjustment, while APA margins cannot govern non-covered years...
Treaty benefit, goodwill depreciation and hedging costs: export commission disallowed, while key business deductions and depreciation claims succeeded...
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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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