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 partially allowed the assessee's appeal regarding amounts found in a diary and surrendered by a director. The Tribunal held that since the surrendered amount represented gross undisclosed income rather than net profit, a lump sum addition of 10 lacs (out of 1.35 crores) was appropriate to cover potential revenue leakage while acknowledging expenditures incurred. Regarding accounting methods, ITAT ruled in favor of the assessee's use of the project completion method rather than percentage completion method. The Tribunal noted this method had been consistently followed and previously accepted by revenue authorities. The Tribunal recognized that immovable property transfers are governed by the Transfer of Property Act, where transfers are complete only upon full payment and possession, making the project completion method appropriate for revenue recognition.
ITAT partially allowed the assessee's appeal regarding amounts found in a diary and surrendered by a director. The Tribunal held that since the surrendered amount represented gross undisclosed income rather than net profit, a lump sum addition of 10 lacs (out of 1.35 crores) was appropriate to cover potential revenue leakage while acknowledging expenditures incurred. Regarding accounting methods, ITAT ruled in favor of the assessee's use of the project completion method rather than percentage completion method. The Tribunal noted this method had been consistently followed and previously accepted by revenue authorities. The Tribunal recognized that immovable property transfers are governed by the Transfer of Property Act, where transfers are complete only upon full payment and possession, making the project completion method appropriate for revenue recognition.
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