https://www.taxtmi.com/caselaws?id=756518 ITAT Mumbai allowed assessee's appeal regarding deferred contingent consideration, holding that such consideration accrued only in AY 2022-23, not AY 2021-22, as the right to receive payment was contingent on revenue targets being met. The tribunal found that accrual occurs only when there is a legally enforceable right to receive the amount. The matter regarding cost of acquisition of shares was remanded to AO for reconsideration of Rs. 56 per share versus Rs. 10 per share. An additional ground concerning Most Favoured Nation clause under India-Netherlands DTAA for dividend taxation at 5% rate was admitted and remanded to AO for fresh adjudication. en-us Wed, 31 Jul 2024 00:00:00 +0530 Mon, 05 Aug 2024 07:05:24 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=756518 ITAT Mumbai allowed assessee's appeal regarding deferred contingent consideration, holding that such consideration accrued only in AY 2022-23, not AY 2021-22, as the right to receive payment was contingent on revenue targets being met. The tribunal found that accrual occurs only when there is a legally enforceable right to receive the amount. The matter regarding cost of acquisition of shares was remanded to AO for reconsideration of Rs. 56 per share versus Rs. 10 per share. An additional ground concerning Most Favoured Nation clause under India-Netherlands DTAA for dividend taxation at 5% rate was admitted and remanded to AO for fresh adjudication. Case-Laws Income Tax Wed, 31 Jul 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=756518