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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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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