Programme production and copyright assignment can be separately taxed when the agreement shows distinct production activity on behalf of the broadcast...
Transshipment permission for courier import goods granted subject to customs supervision, bond compliance, sealing, escort and destination acknowledgm...
Inflated purchase additions attributed to a foreign procurement facilitator were deleted because the entity was separately incorporated, had disclosed its commission income in Singapore, and the Revenue produced no cogent evidence of sham, colourable device, price inflation, fund flow-back, or accrual of the commission income to the assessees; suspicion and uncorroborated statements could not sustain the addition. The Tribunal also treated export incentives as operating income under TNMM, held that persistent loss filters require sustained losses, and applied consistent operating treatment to routine expenses, bad debts, rates and taxes, and marketing commission. It further deleted the section 40A(3) disallowance while confirming a limited disallowance of unsupported expenditure.
Inflated purchase additions attributed to a foreign procurement facilitator were deleted because the entity was separately incorporated, had disclosed its commission income in Singapore, and the Revenue produced no cogent evidence of sham, colourable device, price inflation, fund flow-back, or accrual of the commission income to the assessees; suspicion and uncorroborated statements could not sustain the addition. The Tribunal also treated export incentives as operating income under TNMM, held that persistent loss filters require sustained losses, and applied consistent operating treatment to routine expenses, bad debts, rates and taxes, and marketing commission. It further deleted the section 40A(3) disallowance while confirming a limited disallowance of unsupported expenditure.
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