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 - objections regarding reason to believe raised first time at appellate stage - If reasons recorded upon being challenged at any stage of proceedings falls to withstand the test of judicial scrutiny, in that eventuality, upon such recorded reasons no valid notice can be issued and any assessment framed consequent thereto even taking shelter of ‘no objection’ from the assessee could save the assessment from being held to be declared void-ab-initio and the objection of Revenue was rejected. - AT
Reopening of assessment u/s 147 - objections regarding reason to believe raised first time at appellate stage - If reasons recorded upon being challenged at any stage of proceedings falls to withstand the test of judicial scrutiny, in that eventuality, upon such recorded reasons no valid notice can be issued and any assessment framed consequent thereto even taking shelter of ‘no objection’ from the assessee could save the assessment from being held to be declared void-ab-initio and the objection of Revenue was rejected. - AT
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