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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Exemption u/s 14A read with Rule 8D - disallowance of expenditure attributable to exempt income from partnership firm profits - correctly invoked by AO after recording dissatisfaction, as per Supreme Court ruling in Maxopp Investment Ltd. AO's computation u/r 8D(2) based on assessee's accounts is consonant with IT (14th Amendment) Rules, 2016, applicable from 02.06.2016 for AY 2017-18. CIT(A) erred in deleting disallowance. MAT adjustment u/s 115JB for disallowance u/s 14A - CIT(A) partly correct in not requiring adjustment in book profit for MAT liability, following ITAT Special Bench decisions in Vireet and Radha Madhav cases.
Exemption u/s 14A read with Rule 8D - disallowance of expenditure attributable to exempt income from partnership firm profits - correctly invoked by AO after recording dissatisfaction, as per Supreme Court ruling in Maxopp Investment Ltd. AO's computation u/r 8D(2) based on assessee's accounts is consonant with IT (14th Amendment) Rules, 2016, applicable from 02.06.2016 for AY 2017-18. CIT(A) erred in deleting disallowance. MAT adjustment u/s 115JB for disallowance u/s 14A - CIT(A) partly correct in not requiring adjustment in book profit for MAT liability, following ITAT Special Bench decisions in Vireet and Radha Madhav cases.
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