Pre-commencement R&D deduction denied where business had not commenced; deeming benefit requires tangible start of manufacture or commercial exploitat...
Priority of set-off: brought forward business losses must be adjusted before unabsorbed depreciation; procedural safeguards required for invoking rest...
Change in method of accounting for revenue recognition: Tribunal found the assessee changed the stage-of-completion basis, reversing previously recognised revenue and claiming that reversal as a prior-period deduction which was allowed by the AO and upheld on appeal; this adjustment merely shifted timing of profit recognition without altering tax payable (no loss to the exchequer) and is supported by precedent on timing differences. Consequence: addition made by the AO for the year was unwarranted and is deleted; appeal allowed in favour of the assessee. - ITAT
Change in method of accounting for revenue recognition: Tribunal found the assessee changed the stage-of-completion basis, reversing previously recognised revenue and claiming that reversal as a prior-period deduction which was allowed by the AO and upheld on appeal; this adjustment merely shifted timing of profit recognition without altering tax payable (no loss to the exchequer) and is supported by precedent on timing differences. Consequence: addition made by the AO for the year was unwarranted and is deleted; appeal allowed in favour of the assessee. - ITAT
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