Transfer pricing comparables and adjustments: Tribunal revisits loss-maker status, segmental comparability, working capital relief, and risk allocatio...
Business expenditure disallowance failed where commission, related-party salary and promotion payments were supported by records and inquiry was inade...
GST liability on works executed under pre-GST contracts remains governed exclusively by the applicable GST enactments and cannot be altered by contractual terms or an employer's failure to reimburse differential tax. A contractor's claim for incremental GST reimbursement is confined to the contractual relationship with the concerned employer and does not bind tax authorities. Revised returns, waiver of interest or penalties, and relaxation of statutory limitation cannot be granted through directions arising from a contractual reimbursement dispute, as these matters remain subject to the GST statutory framework. Directions affecting tax authorities or the State beyond that framework were treated as unsustainable.
GST liability on works executed under pre-GST contracts remains governed exclusively by the applicable GST enactments and cannot be altered by contractual terms or an employer's failure to reimburse differential tax. A contractor's claim for incremental GST reimbursement is confined to the contractual relationship with the concerned employer and does not bind tax authorities. Revised returns, waiver of interest or penalties, and relaxation of statutory limitation cannot be granted through directions arising from a contractual reimbursement dispute, as these matters remain subject to the GST statutory framework. Directions affecting tax authorities or the State beyond that framework were treated as unsustainable.
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