Transfer pricing requires evidence for AMP transactions, functionally reliable comparables, and appropriate aggregation or Berry Ratio benchmarking me...
Revisionary jurisdiction cannot reopen share capital assessments where adequate inquiry supports a permissible view and no independent error is establ...
Reassessment jurisdiction fails where unverified portal information is aggregated without examining the taxpayer's explanation or relevance of entries...
Statutory sanction for delayed reassessment requires approval from the prescribed authority; approval by an inferior authority invalidates jurisdictio...
Transfer pricing margin adjustments require matching treatment of non-operating income and related costs, with comparability issues reconsidered on ev...
Preliminary-expense amortisation and MAT exempt-income adjustments prevailed, while trademark costs and managerial remuneration require fresh verifica...
Export valuation requires contemporaneous evidence; unrelated invoices cannot prove overvaluation, and dual penalties on firm and partner are impermis...
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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