Pure reimbursement without income element escapes tax withholding, while delayed withholding and unsupported provisions face deferred or renewed scrut...
Public benefit requirement defeats charitable registration where residents' association services are reciprocal, member-only facilities governed by mu...
Exempt-income expenditure disallowance is confined to investments that actually generated exempt income, while supported business expenses remain dedu...
Objective characteristics and principal use govern mining-tyre classification, while fresh advance ruling applications may rely on additional technica...
Nil ALP cannot be sustained on a benefit test where a franchise payment is for a composite bundle of rights and services; the transfer pricing addition and the alternate Section 37(1) disallowance were deleted because the arrangement was for business purposes and the taxpayer's earlier-year benchmarking had been accepted. On intra-group services, the nil ALP adjustment was also rejected because agreements, invoices and allocation records showed services were received and the tax authorities could not deny deduction by questioning commercial necessity. For purchase of goods, two comparables were excluded, while inclusion of other comparables, margin computation and working capital adjustment were restored for fresh adjudication.
Nil ALP cannot be sustained on a benefit test where a franchise payment is for a composite bundle of rights and services; the transfer pricing addition and the alternate Section 37(1) disallowance were deleted because the arrangement was for business purposes and the taxpayer's earlier-year benchmarking had been accepted. On intra-group services, the nil ALP adjustment was also rejected because agreements, invoices and allocation records showed services were received and the tax authorities could not deny deduction by questioning commercial necessity. For purchase of goods, two comparables were excluded, while inclusion of other comparables, margin computation and working capital adjustment were restored for fresh adjudication.
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