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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The ITAT held that the valuation of inventory must comply with section 145A and ICDS-II, which disallows the LIFO method previously adopted by the assessee. Both opening and closing stock must be valued consistently under ICDS-II to accurately determine profits, preventing distortion of gross profit in the current year. The Tribunal set aside the CIT(A) order and directed the AO to recompute profits for the impugned year strictly as per ICDS-II, adding only the relevant increase for that year. The AO must also assess the impact of ICDS-II adjustments for prior years separately under section 148, recognizing the cumulative effect from the year ICDS-II became applicable. The assessee is permitted to submit detailed calculations of year-wise impacts, and the AO is required to apply the uniform valuation method across all relevant years. The appeal is partly allowed for statistical purposes.
The ITAT held that the valuation of inventory must comply with section 145A and ICDS-II, which disallows the LIFO method previously adopted by the assessee. Both opening and closing stock must be valued consistently under ICDS-II to accurately determine profits, preventing distortion of gross profit in the current year. The Tribunal set aside the CIT(A) order and directed the AO to recompute profits for the impugned year strictly as per ICDS-II, adding only the relevant increase for that year. The AO must also assess the impact of ICDS-II adjustments for prior years separately under section 148, recognizing the cumulative effect from the year ICDS-II became applicable. The assessee is permitted to submit detailed calculations of year-wise impacts, and the AO is required to apply the uniform valuation method across all relevant years. The appeal is partly allowed for statistical purposes.
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