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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The Appellate Tribunal addressed various issues in the case. Firstly, regarding disallowance u/s. 14A r.w.r. 8D, the Tribunal upheld the consistency principle in the methodology of computation accepted in prior years. Secondly, it ruled in favor of the assessee on the nature of expenses, considering expenditure on shelved projects as revenue. Thirdly, it allowed prior period expenditure disallowance based on mercantile accounting. Fourthly, it reversed the disallowance of discount on Euro Notes issuance. Fifthly, it directed the AO to decide on premium deduction impact u/s. 80IA based on previous rulings. Sixthly, it upheld the deduction claim u/s. 80IA for a wind power project. Seventhly, it remanded the issue of duplicate disallowance for re-examination. Lastly, it addressed Transfer Pricing adjustments, including guarantee fees and loan interest, directing the TPO to reconsider certain aspects for TP adjustments.
The Appellate Tribunal addressed various issues in the case. Firstly, regarding disallowance u/s. 14A r.w.r. 8D, the Tribunal upheld the consistency principle in the methodology of computation accepted in prior years. Secondly, it ruled in favor of the assessee on the nature of expenses, considering expenditure on shelved projects as revenue. Thirdly, it allowed prior period expenditure disallowance based on mercantile accounting. Fourthly, it reversed the disallowance of discount on Euro Notes issuance. Fifthly, it directed the AO to decide on premium deduction impact u/s. 80IA based on previous rulings. Sixthly, it upheld the deduction claim u/s. 80IA for a wind power project. Seventhly, it remanded the issue of duplicate disallowance for re-examination. Lastly, it addressed Transfer Pricing adjustments, including guarantee fees and loan interest, directing the TPO to reconsider certain aspects for TP adjustments.
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