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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Three key issues: validity of reopening assessment, treatment of short-term capital gain on sale of factory building, and disallowance of short-term capital loss on share transactions. Regarding reopening, the assessee failed to provide evidence challenging the reassessment proceedings initiated u/s 148. On the factory building sale, the Tribunal upheld adopting the market value as on the conveyance deed date rather than the earlier business transfer agreement date. Concerning the share transactions, the Tribunal upheld the disallowance of claimed capital loss due to lack of evidence justifying the wide fluctuation in share values within a short period and absence of supporting documents like valuation reports, bank statements, and confirmations from counterparties. The Tribunal found no infirmity in the CIT(A)'s order on these issues.
Three key issues: validity of reopening assessment, treatment of short-term capital gain on sale of factory building, and disallowance of short-term capital loss on share transactions. Regarding reopening, the assessee failed to provide evidence challenging the reassessment proceedings initiated u/s 148. On the factory building sale, the Tribunal upheld adopting the market value as on the conveyance deed date rather than the earlier business transfer agreement date. Concerning the share transactions, the Tribunal upheld the disallowance of claimed capital loss due to lack of evidence justifying the wide fluctuation in share values within a short period and absence of supporting documents like valuation reports, bank statements, and confirmations from counterparties. The Tribunal found no infirmity in the CIT(A)'s order on these issues.
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