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 resolved multiple taxation issues in favor of the assessee. The tribunal deleted additions related to undisclosed turnover by recognizing discrepancies between GST and income tax records, specifically noting that capital asset sales are recorded differently in financial statements. Regarding unsecured loans under Section 68, the tribunal found the assessee discharged its evidentiary burden, with the revenue failing to substantiate contrary claims. The tribunal emphasized that additions based on conjecture cannot be sustained, particularly when loan repayments were demonstrated. Consequently, the assessee's appeal was comprehensively allowed, with additions under both disputed grounds being deleted.
ITAT resolved multiple taxation issues in favor of the assessee. The tribunal deleted additions related to undisclosed turnover by recognizing discrepancies between GST and income tax records, specifically noting that capital asset sales are recorded differently in financial statements. Regarding unsecured loans under Section 68, the tribunal found the assessee discharged its evidentiary burden, with the revenue failing to substantiate contrary claims. The tribunal emphasized that additions based on conjecture cannot be sustained, particularly when loan repayments were demonstrated. Consequently, the assessee's appeal was comprehensively allowed, with additions under both disputed grounds being deleted.
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