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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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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