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 revision under section 263 is not warranted where two reasonable views exist, one by the AO and another by the Pr. CIT. The AO's allowance of depreciation at 25% on the opening WDV plus capital expenditure in a BOT road project was upheld, supported by precedent. The Tribunal rejected the Pr. CIT's direction to exclude the negative grant of Rs. 595 crore payable to NHAI from the asset cost, affirming that under the mercantile system, accrued liabilities must be accounted for. The negative grant constituted an ascertained liability upon project completion in AY 2012-13, despite payment being due from the 15th year. The CBDT Circular No. 09/2014 was held inapplicable retrospectively to the assessment year in question. Consequently, the Pr. CIT's revision was quashed, and the assessee's claim for depreciation inclusive of the negative grant was restored, allowing the appeal.
The ITAT held that revision under section 263 is not warranted where two reasonable views exist, one by the AO and another by the Pr. CIT. The AO's allowance of depreciation at 25% on the opening WDV plus capital expenditure in a BOT road project was upheld, supported by precedent. The Tribunal rejected the Pr. CIT's direction to exclude the negative grant of Rs. 595 crore payable to NHAI from the asset cost, affirming that under the mercantile system, accrued liabilities must be accounted for. The negative grant constituted an ascertained liability upon project completion in AY 2012-13, despite payment being due from the 15th year. The CBDT Circular No. 09/2014 was held inapplicable retrospectively to the assessment year in question. Consequently, the Pr. CIT's revision was quashed, and the assessee's claim for depreciation inclusive of the negative grant was restored, allowing the appeal.
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