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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Addition u/s 40A (2) (b) - exponential increase in the Directors’ remuneration - CBDT Circular clearly states that no disallowance is to be made u/s 40A (2) in respect of payments made to relatives and sister concerns where there is no attempt to evade tax. Clearly no case of evasion of tax can be made out in the present appeal. This circular is binding on the Department and since no motive to evade tax is established and further since the AO has not pointed out any comparables to demonstrate that the salary paid to Directors was excessive, - AT
Addition u/s 40A (2) (b) - exponential increase in the Directors’ remuneration - CBDT Circular clearly states that no disallowance is to be made u/s 40A (2) in respect of payments made to relatives and sister concerns where there is no attempt to evade tax. Clearly no case of evasion of tax can be made out in the present appeal. This circular is binding on the Department and since no motive to evade tax is established and further since the AO has not pointed out any comparables to demonstrate that the salary paid to Directors was excessive, - AT
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