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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Reassessment u/s 147 - precluding the Revenue from urging the merits of the issue only because it had not challenged the order of the CIT (A) annulling the re-assessment proceedings is not a mere ‘technical approach’ - there was no basis for the re-opening of the assessment except the presumptive observation of the Revenue audit which itself was not based on any tangible material - no substantial question of law arises
Reassessment u/s 147 - precluding the Revenue from urging the merits of the issue only because it had not challenged the order of the CIT (A) annulling the re-assessment proceedings is not a mere ‘technical approach’ - there was no basis for the re-opening of the assessment except the presumptive observation of the Revenue audit which itself was not based on any tangible material - no substantial question of law arises
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