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...
Functional comparability governs software-service benchmarking: dissimilar companies are excluded, while related-party filters, margins and working-ca...
ITAT permitted non-corporate assessee's change from mercantile to cash accounting system for interest income recognition. The change was deemed legitimate due to borrowers' financial distress and assessee's consistent application in subsequent years. ITAT rejected Revenue's contention to tax unpaid interest income from SPCPL and Roxanna on accrual basis. While SPCPL had not accrued the waived interest in its books, Roxanna, despite accruing the expense, had not paid the interest. CIT(A)'s deletion of AO's addition towards interest income was upheld, acknowledging assessee's right to adopt either accounting method and commitment to declare income upon actual receipt. Revenue's grounds were dismissed.
ITAT permitted non-corporate assessee's change from mercantile to cash accounting system for interest income recognition. The change was deemed legitimate due to borrowers' financial distress and assessee's consistent application in subsequent years. ITAT rejected Revenue's contention to tax unpaid interest income from SPCPL and Roxanna on accrual basis. While SPCPL had not accrued the waived interest in its books, Roxanna, despite accruing the expense, had not paid the interest. CIT(A)'s deletion of AO's addition towards interest income was upheld, acknowledging assessee's right to adopt either accounting method and commitment to declare income upon actual receipt. Revenue's grounds were dismissed.
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