Pharmaceutical promotion and transfer-pricing comparability principles limited disallowances, while uncorroborated search allegations and unsupported ...
Business expenditure substantiation supports scrap credits, statutory payments and expense claims, while depreciation requires proof of actual busines...
Time-share membership fees received upfront were held to be assessable on a deferred basis where the contract imposed continuing obligations to provide accommodation and related facilities over the membership period. The Court applied the matching principle and accepted the assessee's method of accounting, holding that taxing the entire receipt in the year of receipt would distort true profits because the corresponding liability extended into future years. The obligations were treated as real and subsisting, not merely contingent, and annual maintenance and utility charges were viewed as separate from the membership fee. The deferment of part of the fee over the contract tenure was upheld.
Time-share membership fees received upfront were held to be assessable on a deferred basis where the contract imposed continuing obligations to provide accommodation and related facilities over the membership period. The Court applied the matching principle and accepted the assessee's method of accounting, holding that taxing the entire receipt in the year of receipt would distort true profits because the corresponding liability extended into future years. The obligations were treated as real and subsisting, not merely contingent, and annual maintenance and utility charges were viewed as separate from the membership fee. The deferment of part of the fee over the contract tenure was upheld.
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