Transfer-pricing treatment of ITeS margins excludes pass-through tax recoveries and separate delayed-receivables interest after working-capital adjust...
Capacity-utilisation adjustments under TNMM can neutralise substantiated COVID-related idle costs where underutilisation materially affects profitabil...
TNMM functional comparability requires excluding rice manufacturers from a pure Basmati rice trader's benchmark and recognising operating export recei...
Working-capital adjustment subsumes delayed-receivable effects in TNMM benchmarking of captive software-development services, avoiding separate notion...
Transfer-pricing comparability requires exclusion of financially illogical super-profit comparables and correction of unsupported annual-report and ma...
Charitable character assessment preserves Section 80G approval despite inclusive spiritual teachings and incidental religious expenditure within the s...
Penalty proceedings for cash-loan acceptance require assessment proceedings and recorded Assessing Officer satisfaction; absent these, the proceedings...
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Revision u/s 263 - Method of accounting adopted for revenue recognition of the project - The Tribunal decided that the Pr.CIT erred in directing the AO to reassess based on the method of accounting adopted for revenue recognition. It noted that the appellant had consistently followed the project completion method, which had been accepted by the revenue authorities in the past, and the AO had applied his mind to this issue in the assessment. The Tribunal set aside the Pr.CIT's order on this issue, ruling in favor of the appellant.
Revision u/s 263 - Method of accounting adopted for revenue recognition of the project - The Tribunal decided that the Pr.CIT erred in directing the AO to reassess based on the method of accounting adopted for revenue recognition. It noted that the appellant had consistently followed the project completion method, which had been accepted by the revenue authorities in the past, and the AO had applied his mind to this issue in the assessment. The Tribunal set aside the Pr.CIT's order on this issue, ruling in favor of the appellant.
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