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 allowed appellant's appeal regarding double taxation of unbilled revenue. Appellant erroneously offered excess income to tax by accruing unbilled revenue from one customer, which was subsequently taxed again in AY 2019-20 upon invoice generation. Tribunal examined computation statements and revised returns, confirming revenue reduction in FY 2019-20 was added back in AY 2020-21 computation. ITAT found merit in appellant's contention that income was taxed twice - initially as unbilled revenue in respective financial years and again upon invoice raising in the assessment year under consideration. Tribunal directed Assessing Officer to reduce appellant's income by the amount erroneously excess offered to tax, preventing double taxation of the same revenue stream.
ITAT allowed appellant's appeal regarding double taxation of unbilled revenue. Appellant erroneously offered excess income to tax by accruing unbilled revenue from one customer, which was subsequently taxed again in AY 2019-20 upon invoice generation. Tribunal examined computation statements and revised returns, confirming revenue reduction in FY 2019-20 was added back in AY 2020-21 computation. ITAT found merit in appellant's contention that income was taxed twice - initially as unbilled revenue in respective financial years and again upon invoice raising in the assessment year under consideration. Tribunal directed Assessing Officer to reduce appellant's income by the amount erroneously excess offered to tax, preventing double taxation of the same revenue stream.
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