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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Undisclosed 'on money' receipts are taxable only to the extent of the profit element; the profit rate is fact-specific and must be estimated from project stage, cost structure and seized material, and a 10% profit on gross on money was held reasonable on the facts. ICDS III (construction contracts) does not apply to a contractee/developer in this position, and where the assessee follows project completion/percentage of completion, estimated profit on on money is recognised in the year of execution of the sale deed or on transfer of significant risks and rewards, not necessarily on receipt of the cash.
Undisclosed 'on money' receipts are taxable only to the extent of the profit element; the profit rate is fact-specific and must be estimated from project stage, cost structure and seized material, and a 10% profit on gross on money was held reasonable on the facts. ICDS III (construction contracts) does not apply to a contractee/developer in this position, and where the assessee follows project completion/percentage of completion, estimated profit on on money is recognised in the year of execution of the sale deed or on transfer of significant risks and rewards, not necessarily on receipt of the cash.
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