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 assessee followed the correct method of valuing inventory by excluding recoverable VAT from the cost of purchases and inventory, in compliance with Accounting Standard 2 and the Income Computation and Disclosure Standards. The Assessing Officer erred by adding VAT to the closing stock without making corresponding adjustments to the opening stock and purchases. The Inclusive method was correctly applied by the assessee as per Section 145A, resulting in a nil impact on income. The ITAT relied on the Supreme Court's judgment in CIT v. Indo Nippon Chemicals Co. Ltd, which disallowed adopting different methods for purchases and closing stock valuation. Consequently, the addition made by the AO was incorrect and the assessee's appeal was allowed.
The assessee followed the correct method of valuing inventory by excluding recoverable VAT from the cost of purchases and inventory, in compliance with Accounting Standard 2 and the Income Computation and Disclosure Standards. The Assessing Officer erred by adding VAT to the closing stock without making corresponding adjustments to the opening stock and purchases. The Inclusive method was correctly applied by the assessee as per Section 145A, resulting in a nil impact on income. The ITAT relied on the Supreme Court's judgment in CIT v. Indo Nippon Chemicals Co. Ltd, which disallowed adopting different methods for purchases and closing stock valuation. Consequently, the addition made by the AO was incorrect and the assessee's appeal was allowed.
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