Transfer pricing comparability requires functional alignment and permits working capital adjustment, while APA margins cannot govern non-covered years...
Treaty benefit, goodwill depreciation and hedging costs: export commission disallowed, while key business deductions and depreciation claims succeeded...
Undisclosed foreign asset classification requires an unexplained source; unrebutted affidavits and corroborative evidence defeated the Black Money Act...
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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