Supervisory permanent establishment requires project-wise duration and qualifying construction nexus; offshore supplies and salary reimbursements rema...
Transfer-pricing comparability permits fresh objections and filters where software service comparables are functionally unsuitable for arm's-length pr...
Territorial rendering requirement excludes China-based management and consultancy services from fees for technical services under the India-China DTAA...
The ITAT addressed a case involving a change in accounting policy from Percentage of Completion Method (POCM) to Project Completion Method (PCM) for revenue recognition. The assessee declared a net loss due to the change and the AO added the financial impact as profit, resulting in a significantly higher profit than industry average. The ITAT directed the AO to verify the impact in financial statements for both current and previous years, ensuring correct profit calculation. It emphasized that a change in accounting method does not imply profit understatement, as it is a legitimate decision guided by accounting standards. The ITAT upheld the assessee's right to choose the accounting method and instructed the AO to reevaluate the issue, allowing the assessee a fair opportunity to present their case. The assessee's grounds were allowed for statistical purposes.
The ITAT addressed a case involving a change in accounting policy from Percentage of Completion Method (POCM) to Project Completion Method (PCM) for revenue recognition. The assessee declared a net loss due to the change and the AO added the financial impact as profit, resulting in a significantly higher profit than industry average. The ITAT directed the AO to verify the impact in financial statements for both current and previous years, ensuring correct profit calculation. It emphasized that a change in accounting method does not imply profit understatement, as it is a legitimate decision guided by accounting standards. The ITAT upheld the assessee's right to choose the accounting method and instructed the AO to reevaluate the issue, allowing the assessee a fair opportunity to present their case. The assessee's grounds were allowed for statistical purposes.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4886 
