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 jurisdictional HC in the case of Schneider Electric South Asia (HQ) PTE. Ltd. vs. ACIT held that the mere reference to "misreporting" without specifying the limb of Section 270A attracted or satisfying the ingredients of subsection (9) renders the order imposing penalty u/s 270A(9)(a) manifestly arbitrary. Consequently, the levy of penalty u/s 270A(9)(a) was deleted in favor of the assessee.
The jurisdictional HC in the case of Schneider Electric South Asia (HQ) PTE. Ltd. vs. ACIT held that the mere reference to "misreporting" without specifying the limb of Section 270A attracted or satisfying the ingredients of subsection (9) renders the order imposing penalty u/s 270A(9)(a) manifestly arbitrary. Consequently, the levy of penalty u/s 270A(9)(a) was deleted in favor of the assessee.
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