Transfer pricing comparables and operating income principles applied to software development services, with exclusions, inclusions, and tax credit ver...
Transfer pricing on performance guarantees and overdue receivables deleted where warranty obligations were embedded and working capital adjustment alr...
Approval for a trust was upheld because the determinative statutory test was whether expenditure of a religious nature exceeded the prescribed limit of the trust's total income in the relevant year. The Court accepted the Tribunal's finding that the Revenue could not dispute the factual figures showing religious expenditure remained below that limit, so the trust was eligible for approval on that statutory basis despite objections that some objects were religious in nature. The proposed question of law was not entertained, and the appeal was dismissed.
Approval for a trust was upheld because the determinative statutory test was whether expenditure of a religious nature exceeded the prescribed limit of the trust's total income in the relevant year. The Court accepted the Tribunal's finding that the Revenue could not dispute the factual figures showing religious expenditure remained below that limit, so the trust was eligible for approval on that statutory basis despite objections that some objects were religious in nature. The proposed question of law was not entertained, and the appeal was dismissed.
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