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 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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