Dispute Resolution Panel objections must reach both prescribed forums; otherwise assessment may proceed and statutory appeal remains the proper remedy...
Political contribution deductions require recipient party compliance with contribution-reporting conditions; banking-channel donations alone do not qu...
Aggregation under TNMM prevents selective testing of intra-group services without comparable uncontrolled transactions, while appellate additional cla...
Protective assessment cannot duplicate identical receipts under competing characterisations; remote services did not establish a taxable permanent est...
Revenue recognition based on Accounting Standard (AS) 7 for advance received from customers under contracts - assessee followed Percentage Completion Method (PCM) substantiated with sample contracts and explanations filed with tax authorities. Unadjusted advances shown as current liabilities, unbilled revenue as current assets. Method consistently followed and approved by Tribunal in earlier years to match costs with revenues. Advance received for Annual Maintenance Contracts (AMC) accounted as per AS-9, proportionately transferred to revenue each month. Method approved by Tribunal for previous years. Disallowance of TDS recoverable written off covered by assessee's own case. Depreciation claim on intangible assets like know-how, business contracts allowed based on court decisions in assessee's and other cases. Goodwill held as depreciable asset following Supreme Court ruling.
Revenue recognition based on Accounting Standard (AS) 7 for advance received from customers under contracts - assessee followed Percentage Completion Method (PCM) substantiated with sample contracts and explanations filed with tax authorities. Unadjusted advances shown as current liabilities, unbilled revenue as current assets. Method consistently followed and approved by Tribunal in earlier years to match costs with revenues. Advance received for Annual Maintenance Contracts (AMC) accounted as per AS-9, proportionately transferred to revenue each month. Method approved by Tribunal for previous years. Disallowance of TDS recoverable written off covered by assessee's own case. Depreciation claim on intangible assets like know-how, business contracts allowed based on court decisions in assessee's and other cases. Goodwill held as depreciable asset following Supreme Court ruling.
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