Pre-amendment reassessment limitation bars late notices under the preserved regime, invalidating consequential reassessment for affected earlier asses...
Cash-sales explanations for bank deposits require documentary reconciliation; reassessment notice survived where effective response time was available...
Functional comparability in transfer pricing prevents ad hoc arm's length adjustments where functions, assets, risks and reliable comparables are unes...
Contingency expenses, exempt-income disallowance, and royalty benchmarking: unsupported adjustments were deleted under consistent accounting and trans...
ITAT affirmed the application of ICDS III for revenue recognition in construction contracts. The tribunal held that the assessee correctly accounted for total revenue using Percentage of Completion Method (POCM), with a declared total income of Rs. 9,79,75,000 on a gross POCM of Rs. 42,26,67,000. The tribunal found no conflict between ICDS and Income Tax Act, noting that GST invoicing does not impact income computation. The net income margin of 23.18% was deemed reasonable. Consequently, the revenue's appeal was dismissed, upholding the lower appellate authority's deletion of additions made by the Assessing Officer.
ITAT affirmed the application of ICDS III for revenue recognition in construction contracts. The tribunal held that the assessee correctly accounted for total revenue using Percentage of Completion Method (POCM), with a declared total income of Rs. 9,79,75,000 on a gross POCM of Rs. 42,26,67,000. The tribunal found no conflict between ICDS and Income Tax Act, noting that GST invoicing does not impact income computation. The net income margin of 23.18% was deemed reasonable. Consequently, the revenue's appeal was dismissed, upholding the lower appellate authority's deletion of additions made by the Assessing Officer.
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TaxTMI 
TaxTMI 
of 4918 
