Development agreements require legal possession or effective enjoyment for capital gains transfer; permissive possession and deferred consideration de...
Prolonged sterilisation of development rights supports capital-gains treatment, while business-income disallowances cannot govern capital-gains comput...
Additional evidence in transfer pricing dispute leads to fresh examination, while tax deductions, TDS credit, fee and refund interest require verifica...
Category II AIF pass-through taxation preserves non-business income character; investment receipts cannot be reclassified without applying recognised ...
Mutual fund maturity rules require proper rollover, redemption, disclosure, and due diligence; investor gains cannot excuse regulatory breaches or pen...
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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