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 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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