Home Highlights April 2012 Year 2012 This

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1. TP adjustment on account of reimbursement of seafarer expenses - Revenue has only doubted the genuineness of the alleged reimbursement of expenses made by the assessee...

2. Transfer pricing issues: Royalty arrangement including trademark, know-how upheld based on CUP method over TNMM. Advertisement expenses remanded for fresh determination....

3. Expenses Incurred with no income element - Reimbursement of Global Account Management (GAM) charges - These so called expenses without any income element embed in them...

4. Addition u/s 43B - Method of accounting - unpaid statutory dues of service tax, Excise and PF by changing the method of accounting - The assessee followed the exclusive...

5. Revision u/s 263 - Method of accounting adopted for revenue recognition of the project - The Tribunal decided that the Pr.CIT erred in directing the AO to reassess based...

6. Taxation of software reimbursements as Royalty - assessee strongly contends that reimbursements sought by the assessee represent recovery of expenses incurred by it, on...

7. TDS u/s 195 - Payment of Royalty or not - The assessee agreed for reimbursement of cost incurred by the GTRC for doing research activity as a part of joint research on...

8. Addition on account of revenue recognition following percentage of completion method (POCM) - as per AO assessee had incurred substantial expenses on construction but...

9. Rejection of Books of accounts - Method of accounting - Percentage completion method or project completion method - recognition/identification of income under the 1961...

10. Rejection of books of account - Correct method of accounting - following cash system of accounting instead of accrual method of accounting - He has not cared to discuss...

11. Adhoc Addition on account of personal use of car, on account of tour and travelling expenses and on account of telephone expenses - When undisputedly assessee has...

12. TDS u/s 195 - addition u/s 40(a)(i) - computer maintenance expenses - Royalty - The Singapore entity buys various licenses from third party manufacturers and in turn...

13. The ITAT addressed a case involving a change in accounting policy from Percentage of Completion Method (POCM) to Project Completion Method (PCM) for revenue recognition....

14. Penalty u/s 271(1)(c) - TP Adjustment - it is a debatable issue whether reimbursement of expenses qualifies as FTS and there are various decisions which have held that...

15. TDS u/s 195 - disallowance u/s. 40(a)(i) - chargeability of amount to tax in India - rendering of technical services under India-Singapore tax treaty - whether being...