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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TDS u/s 195 - Non-deduction of TDS for legal and professional charges paid - no technical knowledge, skill, experience, knowhow or process is made available to assessee Company in terms of Article 12(b) of the India-US Treaty and Assessee has not defaulted in deducting TDS u/s 195 of the Act. Therefore the disallowance is unwarranted. - AT
TDS u/s 195 - Non-deduction of TDS for legal and professional charges paid - no technical knowledge, skill, experience, knowhow or process is made available to assessee Company in terms of Article 12(b) of the India-US Treaty and Assessee has not defaulted in deducting TDS u/s 195 of the Act. Therefore the disallowance is unwarranted. - AT
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