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...
Reopening of assessment u/s 147 - The assessee had made full disclosure regarding the facts and circumstances in which the said amount was paid. It is obvious that the AO had considered the allowability of such deduction. The AO now seeks to re-assess the assessee’s income on the ground that the amount paid by the assessee to his sisters was not deductible from the sale consideration for the purpose of computing capital gains. This is clearly a case of change of opinion. - HC
Reopening of assessment u/s 147 - The assessee had made full disclosure regarding the facts and circumstances in which the said amount was paid. It is obvious that the AO had considered the allowability of such deduction. The AO now seeks to re-assess the assessee’s income on the ground that the amount paid by the assessee to his sisters was not deductible from the sale consideration for the purpose of computing capital gains. This is clearly a case of change of opinion. - HC
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