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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ITAT adjudicated a complex tax assessment case involving search and seizure proceedings under Section 153A. The tribunal addressed jurisdictional issues regarding unexplained cash deposits and the interpretation of 'other material' during assessment. After divergent opinions from bench members, a third member was consulted. The final outcome involves partially allowing appeals from both the department and assessee, with specific directions to restore matters to CIT(A) for merit-based examination of incriminating and other materials found during search proceedings. The decision emphasizes the nuanced interplay between Sections 153A, 153C, and 147, highlighting the tribunal's careful approach to reassessment and multiple assessment limitations in search-related tax proceedings.
ITAT adjudicated a complex tax assessment case involving search and seizure proceedings under Section 153A. The tribunal addressed jurisdictional issues regarding unexplained cash deposits and the interpretation of 'other material' during assessment. After divergent opinions from bench members, a third member was consulted. The final outcome involves partially allowing appeals from both the department and assessee, with specific directions to restore matters to CIT(A) for merit-based examination of incriminating and other materials found during search proceedings. The decision emphasizes the nuanced interplay between Sections 153A, 153C, and 147, highlighting the tribunal's careful approach to reassessment and multiple assessment limitations in search-related tax proceedings.
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