Service permanent establishment requires non-auxiliary services, while arm's-length distributor remuneration precludes further profit attribution in I...
Make-available condition excludes standard SaaS subscription receipts where customers receive no independently usable technical knowledge after subscr...
Determination of income - The Tribunal agreed with the Ld. CIT(A)'s finding that the assessee, a real estate developer, has consistently followed the Project Completion Method (PCM) for revenue recognition, which was accepted by the department in earlier years. The Tribunal referenced various judicial precedents to assert that the PCM is a recognized method of accounting for real estate developers and that changing the accounting method based on the Guidance Note on Accounting for Real Estate Transactions (Revised 2012) was not justified.
Determination of income - The Tribunal agreed with the Ld. CIT(A)'s finding that the assessee, a real estate developer, has consistently followed the Project Completion Method (PCM) for revenue recognition, which was accepted by the department in earlier years. The Tribunal referenced various judicial precedents to assert that the PCM is a recognized method of accounting for real estate developers and that changing the accounting method based on the Guidance Note on Accounting for Real Estate Transactions (Revised 2012) was not justified.
Note: It is a system-generated summary and is for quick reference only.