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 upheld CIT(A)'s order, dismissing Revenue's appeal. The tribunal confirmed the consistent accounting method for project revenue recognition, rejecting AO's computation of addition under Percentage Completion Method. The tribunal noted the project ultimately resulted in a loss and the assessee's share was incorrectly calculated. The key principles of accounting consistency and proportional revenue recognition were applied, finding no procedural or computational errors in CIT(A)'s original order. The interest expense addition related to land co-owners was also deleted, with the tribunal agreeing that no interest was chargeable on advances. Consequently, the Revenue's appeal was comprehensively dismissed.
ITAT upheld CIT(A)'s order, dismissing Revenue's appeal. The tribunal confirmed the consistent accounting method for project revenue recognition, rejecting AO's computation of addition under Percentage Completion Method. The tribunal noted the project ultimately resulted in a loss and the assessee's share was incorrectly calculated. The key principles of accounting consistency and proportional revenue recognition were applied, finding no procedural or computational errors in CIT(A)'s original order. The interest expense addition related to land co-owners was also deleted, with the tribunal agreeing that no interest was chargeable on advances. Consequently, the Revenue's appeal was comprehensively dismissed.
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