Employee stock-shortage penalties do not constitute consideration for services, preventing GST collection under Schedule II in employment relationship...
Transfer-pricing treatment of ITeS margins excludes pass-through tax recoveries and separate delayed-receivables interest after working-capital adjust...
Capacity-utilisation adjustments under TNMM can neutralise substantiated COVID-related idle costs where underutilisation materially affects profitabil...
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TPA - Adjustment of interest for delayed realization of sale from AE - when the assessee is not charging any interest from non AE then there is no case made out by the revenue that the assessee is doing any favour or giving any benefit to the AE by extending the credit period of realization of sales which is less than the internal CUP being the assessee allowing the credit period to the non-AE - AT
TPA - Adjustment of interest for delayed realization of sale from AE - when the assessee is not charging any interest from non AE then there is no case made out by the revenue that the assessee is doing any favour or giving any benefit to the AE by extending the credit period of realization of sales which is less than the internal CUP being the assessee allowing the credit period to the non-AE - AT
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