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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The article addresses tax treatment of receipts under Annual Maintenance Contracts (AMCs) for A.Y. 2022-23, applying the statutory rule inserted retrospectively from 01.04.2017 that governs recognition of profits from service contracts. It explains that AMCs involve maintenance services performed through an indeterminate number of acts and that the statutory mandate requires use of the straight-line method to determine and recognise revenue over the contract tenure. The piece criticises reliance on prior intra-party precedent for an earlier year where the subsequently operative statutory framework was not considered, and concludes that the addition on AMC receipts should be deleted and revenue spread over the contract period.
The article addresses tax treatment of receipts under Annual Maintenance Contracts (AMCs) for A.Y. 2022-23, applying the statutory rule inserted retrospectively from 01.04.2017 that governs recognition of profits from service contracts. It explains that AMCs involve maintenance services performed through an indeterminate number of acts and that the statutory mandate requires use of the straight-line method to determine and recognise revenue over the contract tenure. The piece criticises reliance on prior intra-party precedent for an earlier year where the subsequently operative statutory framework was not considered, and concludes that the addition on AMC receipts should be deleted and revenue spread over the contract period.
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