Revenue neutrality in domestic related-party loans can require deletion of interest transfer pricing adjustments after domestic-transaction verificati...
Pre-enactment land-sale agreements escape stamp-duty value substitution where substantial banking-channel consideration was received before Section 43...
The Income Tax Appellate Tribunal (ITAT) held that retention money should be included in contract receipts for computing deduction u/s 80-IA for profits from construction activities. Section 43CB, effective from April 1, 2017, clearly provides that for percentage completion method, project completion method or straight-line method, contract revenue shall include retention money. The retention money cannot have different characteristics than the principal contract amount, as both are part of revenue received for construction activities eligible for Section 80-IA deduction. The ITAT relied on Section 43CB and allowed the assessee's appeal, setting aside the CIT(A)'s order disallowing deduction on retention money to the extent of Rs. 11,36,37,740.
The Income Tax Appellate Tribunal (ITAT) held that retention money should be included in contract receipts for computing deduction u/s 80-IA for profits from construction activities. Section 43CB, effective from April 1, 2017, clearly provides that for percentage completion method, project completion method or straight-line method, contract revenue shall include retention money. The retention money cannot have different characteristics than the principal contract amount, as both are part of revenue received for construction activities eligible for Section 80-IA deduction. The ITAT relied on Section 43CB and allowed the assessee's appeal, setting aside the CIT(A)'s order disallowing deduction on retention money to the extent of Rs. 11,36,37,740.
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