Allocation of registration charges: contractual clause overriding statutory presumption allowed as deduction against capital gain after unrebutted doc...
Expenditure tied to investments yielding exempt income restricted to attributable costs; broader disallowance disallowed and adjustments to WDV and mi...
Admissibility of Investigative Statements invalidated reliance on coerced emails and valuation redetermination, resulting in set aside of penalties an...
Classification of printed technical documents: specific Chapter 49.01 entry prevails, enabling claimed customs exemptions for imported manuals and rep...
Under the mercantile system, contingent contractual consideration does not accrue merely because it is stated in an agreement; taxable income requires a vested, unconditional and enforceable right and a corresponding debt due. Where a contractual tranche depends on conditions, step-in rights and deductible costs, uncertainty over receipt and quantification prevents real income from accruing. Accounting Standard-9 requires reasonable certainty of ultimate collection, while later recovery proceedings may corroborate existing uncertainty. Under the percentage completion method, project expenditure carried in work-in-progress may be claimed when corresponding revenue is recognised, provided it relates to the project and is not deducted twice.
Under the mercantile system, contingent contractual consideration does not accrue merely because it is stated in an agreement; taxable income requires a vested, unconditional and enforceable right and a corresponding debt due. Where a contractual tranche depends on conditions, step-in rights and deductible costs, uncertainty over receipt and quantification prevents real income from accruing. Accounting Standard-9 requires reasonable certainty of ultimate collection, while later recovery proceedings may corroborate existing uncertainty. Under the percentage completion method, project expenditure carried in work-in-progress may be claimed when corresponding revenue is recognised, provided it relates to the project and is not deducted twice.
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