Pure-agent exclusion fails where hotel booking facilitators receive third-party services themselves, making entire customer consideration taxable as r...
Transfer pricing requires evidence for AMP transactions, functionally reliable comparables, and appropriate aggregation or Berry Ratio benchmarking me...
Revisionary jurisdiction cannot reopen share capital assessments where adequate inquiry supports a permissible view and no independent error is establ...
Reassessment jurisdiction fails where unverified portal information is aggregated without examining the taxpayer's explanation or relevance of entries...
Statutory sanction for delayed reassessment requires approval from the prescribed authority; approval by an inferior authority invalidates jurisdictio...
Transfer pricing margin adjustments require matching treatment of non-operating income and related costs, with comparability issues reconsidered on ev...
Preliminary-expense amortisation and MAT exempt-income adjustments prevailed, while trademark costs and managerial remuneration require fresh verifica...
Export valuation requires contemporaneous evidence; unrelated invoices cannot prove overvaluation, and dual penalties on firm and partner are impermis...
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Under the project completion method, only costs that directly bring inventory to its present location and condition may be included in work-in-progress. Expenditure on advertisement, business promotion and commission to agents was treated as promotional and general business outgoings, so it remained revenue expenditure in the year incurred and could not be loaded into project cost merely because revenue had not yet been recognised. By contrast, loan processing charges and security expenses were found to be project-specific and directly connected with the project, so they had to be capitalised as part of work-in-progress.
Under the project completion method, only costs that directly bring inventory to its present location and condition may be included in work-in-progress. Expenditure on advertisement, business promotion and commission to agents was treated as promotional and general business outgoings, so it remained revenue expenditure in the year incurred and could not be loaded into project cost merely because revenue had not yet been recognised. By contrast, loan processing charges and security expenses were found to be project-specific and directly connected with the project, so they had to be capitalised as part of work-in-progress.
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