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...
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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