Permanent-establishment reassessment cannot revisit scrutinised disclosures; extended reopening fails without undisclosed material facts and within st...
Modified returns after business reorganisation must be assessed within pending proceedings, barring parallel scrutiny and consequential transfer prici...
Turnover mismatches under percentage-completion accounting cannot alone establish suppressed income where customer advances remain recorded as liabili...
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Capital grants, subsidies and consumer contributions reduce the actual cost or written-down value of relevant assets for depreciation. Where not directly attributable to a particular asset, they require allocation among the affected assets at their respective depreciation rates. Book-profit adjustments for such grants, including subsidy grants received in advance, require an identified clause in the Explanation to section 115JB(2); treatment under normal tax provisions alone is insufficient. Borrowing-cost capitalisation depends on direct attribution to qualifying capital projects and cannot rest on an unsupported assumed historical rate or unsubstantiated accounting-method change. Assistance for beneficiary-owned solar systems is revenue in nature, while business-linked staff-loan interest and miscellaneous receipts are business income; residual rental and staff recoveries may be income from other sources.
Capital grants, subsidies and consumer contributions reduce the actual cost or written-down value of relevant assets for depreciation. Where not directly attributable to a particular asset, they require allocation among the affected assets at their respective depreciation rates. Book-profit adjustments for such grants, including subsidy grants received in advance, require an identified clause in the Explanation to section 115JB(2); treatment under normal tax provisions alone is insufficient. Borrowing-cost capitalisation depends on direct attribution to qualifying capital projects and cannot rest on an unsupported assumed historical rate or unsubstantiated accounting-method change. Assistance for beneficiary-owned solar systems is revenue in nature, while business-linked staff-loan interest and miscellaneous receipts are business income; residual rental and staff recoveries may be income from other sources.
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