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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HC held that despite considering three block periods of limitation exclusion as per SC precedents, the re-assessment notice dated 23 July 2022 exceeded statutory limitation. The court specifically noted that even after adding 14 days for assessee's response to Section 148A(b) notice, the reassessment remained time-barred. Consequently, the writ petition was allowed, and the Section 148 notice was quashed, effectively invalidating the reassessment proceedings due to procedural time limitations.
HC held that despite considering three block periods of limitation exclusion as per SC precedents, the re-assessment notice dated 23 July 2022 exceeded statutory limitation. The court specifically noted that even after adding 14 days for assessee's response to Section 148A(b) notice, the reassessment remained time-barred. Consequently, the writ petition was allowed, and the Section 148 notice was quashed, effectively invalidating the reassessment proceedings due to procedural time limitations.
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