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 upheld the addition of retention money to contract revenue under Section 43CB and ICDS-III for AY 2017-18, rejecting the appellant's contention that retention money could be excluded despite the statutory amendment effective 01.04.2017. The tribunal affirmed the mercantile system of accounting requires accrual-based income recognition, including retention money, regardless of actual receipt in later years. Pre-amendment case law was held inapplicable due to the express legislative change. However, the ITAT remitted the matter to the AO to verify whether the retention amounts were taxed in AY 2019-20 and 2020-21 and, if so, directed deletion of the addition for AY 2017-18 to avoid double taxation, with consequential appeal effect orders to be passed. The addition relating to AY 2017-18 was otherwise confirmed.
The ITAT upheld the addition of retention money to contract revenue under Section 43CB and ICDS-III for AY 2017-18, rejecting the appellant's contention that retention money could be excluded despite the statutory amendment effective 01.04.2017. The tribunal affirmed the mercantile system of accounting requires accrual-based income recognition, including retention money, regardless of actual receipt in later years. Pre-amendment case law was held inapplicable due to the express legislative change. However, the ITAT remitted the matter to the AO to verify whether the retention amounts were taxed in AY 2019-20 and 2020-21 and, if so, directed deletion of the addition for AY 2017-18 to avoid double taxation, with consequential appeal effect orders to be passed. The addition relating to AY 2017-18 was otherwise confirmed.
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