https://www.taxtmi.com/caselaws?id=436543 ITAT Pune allowed the assessee's appeal and deleted the addition made as "profits in lieu of salary" under section 17(3)(iii) of the Act. The Tribunal held that the ex-gratia amount received from the erstwhile employer, partly claimed as exempt VRS compensation under section 10(10C) and the balance treated as capital receipt, was supported by an employer's letter stating the payment was voluntary and out of appreciation, not compensation. As the Revenue neither challenged the genuineness of this letter nor produced evidence of any legal obligation to pay, invoking section 17(3)(iii) without such inquiry was held arbitrary. en-us Mon, 03 Apr 2023 00:00:00 +0530 Wed, 26 Nov 2025 16:45:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=436543 ITAT Pune allowed the assessee's appeal and deleted the addition made as "profits in lieu of salary" under section 17(3)(iii) of the Act. The Tribunal held that the ex-gratia amount received from the erstwhile employer, partly claimed as exempt VRS compensation under section 10(10C) and the balance treated as capital receipt, was supported by an employer's letter stating the payment was voluntary and out of appreciation, not compensation. As the Revenue neither challenged the genuineness of this letter nor produced evidence of any legal obligation to pay, invoking section 17(3)(iii) without such inquiry was held arbitrary. Case-Laws Income Tax Mon, 03 Apr 2023 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=436543