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 High Court examined the method of valuation of stock and the application of the principle of consistency and regularity. It held that while the principle of consistency remains the same across assessment years, the valuation may change due to fluctuations in market prices and sale prices. The court agreed with the Assessing Officer's view that the average market price could not be used by the assessee because sale prices vary yearly. Regarding the decision in CIT vs. British Paints India Ltd, the court clarified that it was based on specific facts and cannot be treated as a binding precedent in all cases where sale prices change annually. The court ruled in favor of the revenue on both issues related to the method of stock valuation.
The High Court examined the method of valuation of stock and the application of the principle of consistency and regularity. It held that while the principle of consistency remains the same across assessment years, the valuation may change due to fluctuations in market prices and sale prices. The court agreed with the Assessing Officer's view that the average market price could not be used by the assessee because sale prices vary yearly. Regarding the decision in CIT vs. British Paints India Ltd, the court clarified that it was based on specific facts and cannot be treated as a binding precedent in all cases where sale prices change annually. The court ruled in favor of the revenue on both issues related to the method of stock valuation.
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