Transfer pricing comparability requires functional alignment, reliable financial data, and careful review of working capital and receivables adjustmen...
Transfer pricing rules require benchmarking corporate guarantees and associated-enterprise advances, while invalid domestic-transaction adjustments ca...
Prospective sugar export prohibition required registered letters of credit; private contracts and export quotas created no enforceable continuation ri...
Retroactive interim-moratorium exclusion permits protective asset disclosure and preservation measures against personal guarantors pending arbitration...
Assessee followed system of regularly showing mobilization account and advances received, offering income against bills in subsequent years. Revenue did not previously object to this treatment. CIT(Appeals) and Tribunal deleted additions made by Assessing Officer on account of "Mobilization Advance" for the year. Statements of Samiti members showed lack of full knowledge on work progress, with Sub Divisional Engineer overseeing the matter. Work completion certificates indicated work was completed later and income offered for taxation in subsequent years. Non-commensurate work-in-progress amount of Rs. 69,31,666 did not justify treating advances as income. Assessing Officer added Rs. 2,00,95,900 as unaccounted receipts from Samiti, failing to note it was already shown as liability in books. No instance to interfere with CIT(Appeals) observations. CIT(Appeals) order upholding dismissal of Revenue's grounds was affirmed.
Assessee followed system of regularly showing mobilization account and advances received, offering income against bills in subsequent years. Revenue did not previously object to this treatment. CIT(Appeals) and Tribunal deleted additions made by Assessing Officer on account of "Mobilization Advance" for the year. Statements of Samiti members showed lack of full knowledge on work progress, with Sub Divisional Engineer overseeing the matter. Work completion certificates indicated work was completed later and income offered for taxation in subsequent years. Non-commensurate work-in-progress amount of Rs. 69,31,666 did not justify treating advances as income. Assessing Officer added Rs. 2,00,95,900 as unaccounted receipts from Samiti, failing to note it was already shown as liability in books. No instance to interfere with CIT(Appeals) observations. CIT(Appeals) order upholding dismissal of Revenue's grounds was affirmed.
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