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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Reopening of assessment u/s 147 - True and full disclosure of all material facts - It is true that in the assessment order self-disallowances have not been discussed but at the same time it has been a subject of consideration during the assessment proceedings since the Assessing Officer has started from the business income as returned by petitioner, which included self-disallowances debited to the P&L Account. - it is a clear case of change of opinion to take a different view relying on the same set of documents. Change in opinion cannot construe “reason to believe”. - HC
Reopening of assessment u/s 147 - True and full disclosure of all material facts - It is true that in the assessment order self-disallowances have not been discussed but at the same time it has been a subject of consideration during the assessment proceedings since the Assessing Officer has started from the business income as returned by petitioner, which included self-disallowances debited to the P&L Account. - it is a clear case of change of opinion to take a different view relying on the same set of documents. Change in opinion cannot construe “reason to believe”. - HC
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