Income-tax prosecution fails when appellate remand removes its factual foundation; directors require company arraignment for vicarious criminal liabil...
Capital character of assignment consideration prevents taxation as residuary income, while unsupported interest-related expenditure remains non-deduct...
Make-available condition shields regional support-service receipts from Indian taxation where no independent capability or permanent establishment exi...
Transfer-pricing treatment of corporate guarantees and convertible loans followed prior-year consistency, with taxable foreign dividends excluded from...
Transfer-pricing benchmarking confines adjustments to associated-enterprise transactions and integrates delayed receivables through TNMM working-capit...
Medical relief status protects government-contracted mobile healthcare from commercial classification, while provisional registration cancellation req...
Charitable registration cancellation requires proof that educational activities abandoned their objects; incidental receipts and retained surplus are ...
Project-completion accounting, when consistently followed by a real estate developer, is a recognised method and cannot be rejected merely because substantial sale proceeds were received or the Assessing Officer preferred a different revenue-recognition method. Rejection under section 145 was unsustainable because no specific defect showed that the accounts were unreliable, while estimated profit was applied to recorded receipts without an independent basis. Differing flat agreement values also did not establish undisclosed consideration without cogent evidence of actual on-money receipts. Payments for extra work under separate agreements could not be attributed to the developer solely through a director's connection. The book rejection and additions were deleted.
Project-completion accounting, when consistently followed by a real estate developer, is a recognised method and cannot be rejected merely because substantial sale proceeds were received or the Assessing Officer preferred a different revenue-recognition method. Rejection under section 145 was unsustainable because no specific defect showed that the accounts were unreliable, while estimated profit was applied to recorded receipts without an independent basis. Differing flat agreement values also did not establish undisclosed consideration without cogent evidence of actual on-money receipts. Payments for extra work under separate agreements could not be attributed to the developer solely through a director's connection. The book rejection and additions were deleted.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4884 
