Functional comparability governs software-service benchmarking: dissimilar companies are excluded, while related-party filters, margins and working-ca...
The dominant issue was whether revenue from sale of flats had to be recognized in the year under the percentage completion method due to alleged crossing of a 25% threshold, despite the assessee consistently following the project completion method. Since the assessee had offered the same sales to tax in subsequent years upon project completion, forcing recognition in the impugned year would cause impermissible double taxation; further, consistency in accepted accounting treatment could not be disturbed absent any change in facts. Accordingly, the addition for unrecognized revenue was deleted. The issue of disallowance of interest under sections 36(1)(iii) and 40A(2)(a) failed because the interest was not claimed in the profit and loss account but capitalized as work-in-progress, so no deduction was to be disallowed. - ITAT
The dominant issue was whether revenue from sale of flats had to be recognized in the year under the percentage completion method due to alleged crossing of a 25% threshold, despite the assessee consistently following the project completion method. Since the assessee had offered the same sales to tax in subsequent years upon project completion, forcing recognition in the impugned year would cause impermissible double taxation; further, consistency in accepted accounting treatment could not be disturbed absent any change in facts. Accordingly, the addition for unrecognized revenue was deleted. The issue of disallowance of interest under sections 36(1)(iii) and 40A(2)(a) failed because the interest was not claimed in the profit and loss account but capitalized as work-in-progress, so no deduction was to be disallowed. - ITAT
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