Pre-amendment reassessment limitation bars late notices under the preserved regime, invalidating consequential reassessment for affected earlier asses...
Cash-sales explanations for bank deposits require documentary reconciliation; reassessment notice survived where effective response time was available...
Functional comparability in transfer pricing prevents ad hoc arm's length adjustments where functions, assets, risks and reliable comparables are unes...
Contingency expenses, exempt-income disallowance, and royalty benchmarking: unsupported adjustments were deleted under consistent accounting and trans...
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The assessee followed the project completion method for income recognition since inception. The transitional provisions stipulate that for projects commenced before March 31, 2016, but not completed by that date, revenue recognition shall be based on the method regularly followed prior to April 1, 2016. The Assessing Officer's application of the percentage completion method based on ICDS III by partially interpreting it was unjustified. The addition made by the Assessing Officer for the year under consideration by applying the percentage completion method was not justified and was set aside. The assessee's appeal was allowed.
The assessee followed the project completion method for income recognition since inception. The transitional provisions stipulate that for projects commenced before March 31, 2016, but not completed by that date, revenue recognition shall be based on the method regularly followed prior to April 1, 2016. The Assessing Officer's application of the percentage completion method based on ICDS III by partially interpreting it was unjustified. The addition made by the Assessing Officer for the year under consideration by applying the percentage completion method was not justified and was set aside. The assessee's appeal was allowed.
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