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...
Validity of the draft assessment order issued in the name of non-existent entity - TP adjustment - arm’s-length price u/s 92CA - once the draft assessment order and Transfer pricing order itself are bad in law, having been passed in the name of a non-existent entity, then the final assessment order based on the above orders is void ab initio as well. In view of the above settled position of law, we are of the view that the final assessment order sought to be appeal against is void and hence liable to be set aside. Decided in favour of assessee. - AT
Validity of the draft assessment order issued in the name of non-existent entity - TP adjustment - arm’s-length price u/s 92CA - once the draft assessment order and Transfer pricing order itself are bad in law, having been passed in the name of a non-existent entity, then the final assessment order based on the above orders is void ab initio as well. In view of the above settled position of law, we are of the view that the final assessment order sought to be appeal against is void and hence liable to be set aside. Decided in favour of assessee. - AT
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