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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Proof of pudding is in the eating. The travel of assessee from losses to profits pursuant to the collaboration with the Arkadin SA, France is evident. Its acquisition of not only the equipment but also the technical knowhow cannot be presumed to be without any cost. As rightly pointed out by the Ld. CIT(A), the findings of the Assessing Officer that the payments were made without any business purpose and without any commensurate benefit to the assessee are not based on any cogent material and without bringing any adverse material on record.
Proof of pudding is in the eating. The travel of assessee from losses to profits pursuant to the collaboration with the Arkadin SA, France is evident. Its acquisition of not only the equipment but also the technical knowhow cannot be presumed to be without any cost. As rightly pointed out by the Ld. CIT(A), the findings of the Assessing Officer that the payments were made without any business purpose and without any commensurate benefit to the assessee are not based on any cogent material and without bringing any adverse material on record.
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