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...
TNMM functional comparability requires excluding rice manufacturers from a pure Basmati rice trader's benchmark and recognising operating export recei...
Working-capital adjustment subsumes delayed-receivable effects in TNMM benchmarking of captive software-development services, avoiding separate notion...
Transfer-pricing comparability requires exclusion of financially illogical super-profit comparables and correction of unsupported annual-report and ma...
Charitable character assessment preserves Section 80G approval despite inclusive spiritual teachings and incidental religious expenditure within the s...
Penalty proceedings for cash-loan acceptance require assessment proceedings and recorded Assessing Officer satisfaction; absent these, the proceedings...
Functional comparability governs software-service benchmarking: dissimilar companies are excluded, while related-party filters, margins and working-ca...
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.