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 - There remains no ambiguity to the fact that there was no document found from the search premises belonging to the assessee. Therefore the assessment in itself is bad in law. - Thus we hold that the assessment framed under section 153C read with section 143(3) of the Act is not sustainable. Once the assessment in itself is invalid then the same cannot be revised under the provisions of section 263. - AT
Revision u/s 263 by CIT - There remains no ambiguity to the fact that there was no document found from the search premises belonging to the assessee. Therefore the assessment in itself is bad in law. - Thus we hold that the assessment framed under section 153C read with section 143(3) of the Act is not sustainable. Once the assessment in itself is invalid then the same cannot be revised under the provisions of section 263. - AT
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