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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Revision u/s 263 by CIT - - in the present appeals, the assessment orders have already been cancelled – meaning thereby it has extinguished, and therefore, no subsequent further proceedings can be initiated - Commissioner has committed an error by holding that “since the Revenue wants to keep the issue alive, it is necessary to pass such order”. Therefore, in view of the above discussions, the impugned orders are not sustainable in these assessment years. - AT
Revision u/s 263 by CIT - - in the present appeals, the assessment orders have already been cancelled – meaning thereby it has extinguished, and therefore, no subsequent further proceedings can be initiated - Commissioner has committed an error by holding that “since the Revenue wants to keep the issue alive, it is necessary to pass such order”. Therefore, in view of the above discussions, the impugned orders are not sustainable in these assessment years. - AT
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