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 ITAT quashed the order of the Pr. CIT, holding that the addition u/s 56(2)(x) on differential between stamp duty valuation and purchase price was not justified. The ITAT observed that the AO had enquired and was satisfied with the assessee's contention regarding the Joint Development Agreement (JDA). The ITAT noted that taxable income u/s 45(5A) would arise only upon obtaining a completion certificate, which was not the case here. The ITAT found that the Pr. CIT's order was based on assumptions without backing of facts, contrary to the prudent businessman principle. Consequently, the ITAT ruled in favor of the assessee.
The ITAT quashed the order of the Pr. CIT, holding that the addition u/s 56(2)(x) on differential between stamp duty valuation and purchase price was not justified. The ITAT observed that the AO had enquired and was satisfied with the assessee's contention regarding the Joint Development Agreement (JDA). The ITAT noted that taxable income u/s 45(5A) would arise only upon obtaining a completion certificate, which was not the case here. The ITAT found that the Pr. CIT's order was based on assumptions without backing of facts, contrary to the prudent businessman principle. Consequently, the ITAT ruled in favor of the assessee.
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