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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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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