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 tax assessment reopening case, determining the Income Tax Officer's (ITO) jurisdiction to issue notice under Section 148. The tribunal found that since the value of income escaping assessment was below Rs. 50 lakhs, the ITO lacked legal authority to issue the notice as per Section 149(1)(b). Consistent with precedents from Bombay HC and Madhya Pradesh HC, the tribunal quashed the Section 148A(d) order and consequential assessment order, ruling the notice was procedurally invalid and without jurisdictional merit.
ITAT adjudicated a tax assessment reopening case, determining the Income Tax Officer's (ITO) jurisdiction to issue notice under Section 148. The tribunal found that since the value of income escaping assessment was below Rs. 50 lakhs, the ITO lacked legal authority to issue the notice as per Section 149(1)(b). Consistent with precedents from Bombay HC and Madhya Pradesh HC, the tribunal quashed the Section 148A(d) order and consequential assessment order, ruling the notice was procedurally invalid and without jurisdictional merit.
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