Employee stock-shortage penalties do not constitute consideration for services, preventing GST collection under Schedule II in employment relationship...
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...
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ITAT ruled that under mercantile accounting, income accrues only when there exists a legal right to receive it, not merely based on book entries. In the disputed case, enhanced charges recorded in books were unrecoverable due to consumer litigation. Following the 'real income' doctrine established in precedent cases, ITAT held that hypothetical or unilateral book entries without acceptance from debtors do not constitute taxable income. The tribunal emphasized that even in mercantile accounting, income must actually become due and not remain a mere claim. Addition was deleted as no real income had accrued to the assessee, aligning with established judicial principles on income recognition and taxability.
ITAT ruled that under mercantile accounting, income accrues only when there exists a legal right to receive it, not merely based on book entries. In the disputed case, enhanced charges recorded in books were unrecoverable due to consumer litigation. Following the 'real income' doctrine established in precedent cases, ITAT held that hypothetical or unilateral book entries without acceptance from debtors do not constitute taxable income. The tribunal emphasized that even in mercantile accounting, income must actually become due and not remain a mere claim. Addition was deleted as no real income had accrued to the assessee, aligning with established judicial principles on income recognition and taxability.
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