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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Provision for warranty expenses computed on basis of past experience and scientific basis is allowable. Assessee applied formula for provision though no past history was available. Claim based on formula was allowed in subsequent years. Assessee maintained accounts on accrual basis and claimed expenses were actually incurred in subsequent year. Allowability of expenses in year of payment cannot be allowed as accounts are maintained on mercantile system. Nature of expenses being business cannot be lost. Actual incurrence proves provision computed on formula is correct. Supreme Court held provision for warranty on sophisticated goods is deductible u/s 37 if defects existed. Assessee demonstrated defects occurred and rectified during warranty period. Impugned expenses to be allowed after verifying actual incurrence during unexpired warranty period.
Provision for warranty expenses computed on basis of past experience and scientific basis is allowable. Assessee applied formula for provision though no past history was available. Claim based on formula was allowed in subsequent years. Assessee maintained accounts on accrual basis and claimed expenses were actually incurred in subsequent year. Allowability of expenses in year of payment cannot be allowed as accounts are maintained on mercantile system. Nature of expenses being business cannot be lost. Actual incurrence proves provision computed on formula is correct. Supreme Court held provision for warranty on sophisticated goods is deductible u/s 37 if defects existed. Assessee demonstrated defects occurred and rectified during warranty period. Impugned expenses to be allowed after verifying actual incurrence during unexpired warranty period.
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