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 case pertains to the treatment of income received from an arbitral award in the assessment year. The AO passed an assessment order u/s 143(3) after the case was selected for scrutiny through CASS. The ITAT recorded that the AO issued a statutory notice u/s 142(1) with a specific query about the Nardana Claim-1 & Nardana Claim-2, and the assessee filed a cogent reply. The AO's approach in accepting the assessee's explanation regarding the recognition of liability for Nardana Claim-1 & Nardana Claim-2 as income in the AY 2018-19 was found sustainable. The amount was paid to the assessee in AY 2018-19 after furnishing a 100% bank guarantee on 100% margin, and it was rightly shown as a liability in the balance sheet. The income was shown in the next assessment year, i.e., 2019-20, after the Dhule Court's order in favor of the assessee. The ITAT did not find fault in the assessee's approach, considering the law laid down in the Hindustan Housing & Land Development Trust Limited case, where it was held that as long as there remains a dispute/litigation, the income cannot be said to have 'accrued' or '.
The case pertains to the treatment of income received from an arbitral award in the assessment year. The AO passed an assessment order u/s 143(3) after the case was selected for scrutiny through CASS. The ITAT recorded that the AO issued a statutory notice u/s 142(1) with a specific query about the Nardana Claim-1 & Nardana Claim-2, and the assessee filed a cogent reply. The AO's approach in accepting the assessee's explanation regarding the recognition of liability for Nardana Claim-1 & Nardana Claim-2 as income in the AY 2018-19 was found sustainable. The amount was paid to the assessee in AY 2018-19 after furnishing a 100% bank guarantee on 100% margin, and it was rightly shown as a liability in the balance sheet. The income was shown in the next assessment year, i.e., 2019-20, after the Dhule Court's order in favor of the assessee. The ITAT did not find fault in the assessee's approach, considering the law laid down in the Hindustan Housing & Land Development Trust Limited case, where it was held that as long as there remains a dispute/litigation, the income cannot be said to have 'accrued' or '.
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