Pre-existing operational debt disputes require genuine evidence, while undirected running-account payments may be appropriated on a first-in-first-out...
Agency in CNG distribution makes outlet operators commission agents, rendering taxable Business Auxiliary Service rather than purchasing goods for res...
Composite inpatient healthcare supply may retain exemption despite MRP medicine billing, while separate taxable sale characterisation remains disputed...
Working-capital adjustment determines whether software-services transfer-pricing margins fall within the statutory tolerance range, eliminating any ad...
Permanent establishment deductions upheld for expatriate salaries, direct costs and trading losses, while head-office costs require fresh classificati...
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Bad-debt deduction after 1 April 1989 requires write-off in the accounts and satisfaction of the condition that the debt was considered in computing income; actual irrecoverability need not be established. The notes state that revision under section 263 is impermissible where the assessment record shows that the Assessing Officer examined the claim and supporting evidence. They also explain that reconciled contract receipts cannot be treated as understated merely because bank credits include mobilisation, material or other non-revenue advances. A reasoned assessment order is not required where documentary replies have been examined and accepted.
Bad-debt deduction after 1 April 1989 requires write-off in the accounts and satisfaction of the condition that the debt was considered in computing income; actual irrecoverability need not be established. The notes state that revision under section 263 is impermissible where the assessment record shows that the Assessing Officer examined the claim and supporting evidence. They also explain that reconciled contract receipts cannot be treated as understated merely because bank credits include mobilisation, material or other non-revenue advances. A reasoned assessment order is not required where documentary replies have been examined and accepted.
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