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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Dispute concerns revenue recognition where the assessing officer treated finished goods/advances as sales despite the assessee following the project completion method. The tribunal found that the amounts were offered to tax in subsequent assessment years and taxed on profits thereon, making the AO's estimate result in double taxation; accordingly the addition treating such stock/advances as turnover was deleted. Reliance on precedents supporting deletion where income is taxed in later years was noted. Resultantly, all grounds of appeal raising this treatment were allowed and the impugned additions were set aside.
Dispute concerns revenue recognition where the assessing officer treated finished goods/advances as sales despite the assessee following the project completion method. The tribunal found that the amounts were offered to tax in subsequent assessment years and taxed on profits thereon, making the AO's estimate result in double taxation; accordingly the addition treating such stock/advances as turnover was deleted. Reliance on precedents supporting deletion where income is taxed in later years was noted. Resultantly, all grounds of appeal raising this treatment were allowed and the impugned additions were set aside.
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