Transfer pricing adjustments for software services, corporate guarantees, expense characterisation and foreign tax credit affirmed under arm's length ...
Scientific Research approval for Sikshya O Anusandhan under section 35(1)(ii) granted subject to reporting, certification, and compliance requirements...
The dominant issue was whether the percentage completion method under s. 43CB applies to real-estate business for estimating business profit, thereby sustaining additions toward estimated business income and deemed rental income. The appellate authority held that s. 43CB mandatorily applies to real-estate projects and, following binding precedent, rejected the taxpayer's contention that the provision was inapplicable; consequently, the additions made under s. 43CB were confirmed. As no material was produced to rebut these findings, the tribunal declined to interfere and dismissed the appeal. - ITAT
The dominant issue was whether the percentage completion method under s. 43CB applies to real-estate business for estimating business profit, thereby sustaining additions toward estimated business income and deemed rental income. The appellate authority held that s. 43CB mandatorily applies to real-estate projects and, following binding precedent, rejected the taxpayer's contention that the provision was inapplicable; consequently, the additions made under s. 43CB were confirmed. As no material was produced to rebut these findings, the tribunal declined to interfere and dismissed the appeal. - ITAT
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