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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The case involves a challenge to the amendment in Section 145A, making it mandatory to adopt FIFO or weighted average cost method for valuing closing and opening stock. The court held that prior to the amendment, there was no mandatory provision for a specific valuation method. The Parliament made Clause 16 of ICDS (II) mandatory for all assesses, ensuring uniformity in accounting. The court emphasized that the method used for valuing opening and closing stock must be consistent. The retrospective amendment in Section 145A aims to provide relief to assesses who adopted FIFO in the Assessment Year 2017-18. Assessors following LIFO consistently are not required to switch to FIFO for that year. The court partly allowed the writ petitions, quashing the notices and allowing assesses to value stocks using LIFO or FIFO methods for the relevant assessment year.
The case involves a challenge to the amendment in Section 145A, making it mandatory to adopt FIFO or weighted average cost method for valuing closing and opening stock. The court held that prior to the amendment, there was no mandatory provision for a specific valuation method. The Parliament made Clause 16 of ICDS (II) mandatory for all assesses, ensuring uniformity in accounting. The court emphasized that the method used for valuing opening and closing stock must be consistent. The retrospective amendment in Section 145A aims to provide relief to assesses who adopted FIFO in the Assessment Year 2017-18. Assessors following LIFO consistently are not required to switch to FIFO for that year. The court partly allowed the writ petitions, quashing the notices and allowing assesses to value stocks using LIFO or FIFO methods for the relevant assessment year.
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