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...
Anonymous donation classification fails where charitable trusts maintain undisputed donor identity records and evidence corpus contributions' intended...
Transfer pricing method selection favours TNMM where medical-equipment distribution involves substantial post-import value addition and operational ri...
Post-export shipping bill conversion remains available where contemporaneous evidence supports EPCG benefits despite curable procedural omissions and ...
Addition on account of revenue recognition following percentage of completion method (POCM) - as per AO assessee had incurred substantial expenses on construction but the revenue had not been recognized on the basis of percentage of completion method - It was found by the ITAT that the Assessee had already shown 98.62% of the total revenue in subsequent years based on POCM. The Tribunal agreed with the Assessee's contention that revenue recognition based on POCM in the current year would lead to complications and would not benefit the Revenue. - The addition made by the Assessing Officer was deleted based on these findings.
Addition on account of revenue recognition following percentage of completion method (POCM) - as per AO assessee had incurred substantial expenses on construction but the revenue had not been recognized on the basis of percentage of completion method - It was found by the ITAT that the Assessee had already shown 98.62% of the total revenue in subsequent years based on POCM. The Tribunal agreed with the Assessee's contention that revenue recognition based on POCM in the current year would lead to complications and would not benefit the Revenue. - The addition made by the Assessing Officer was deleted based on these findings.
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