Section 80JJAA employee-cost deduction allowed for deployed staff but barred against transfer-pricing income enhancement, with pricing issues remanded...
Transfer-pricing methodology protects commercially genuine associated-enterprise payments, while pre-2016 secondary adjustments and related notional i...
Negative liens over operating assets can constitute international transactions requiring arm's-length pricing reflecting restricted borrowing and expa...
Cross-examination rights in Customs Broker revocation inquiries require witness examination; procedural denial may be cured through fresh adjudication...
Governmental authority status supports construction-service exemption, while pre-cutoff contract and stamp-duty compliance requires verification on re...
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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.
Note: It is a system-generated summary and is for quick reference only.