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...
Direct assessment of a beneficiary under representative assessee provisions does not dispense with prior determination of the trust's income or loss. The Tribunal found that, where the trust was created by a duly executed instrument, its trustees had to be assessed in that representative capacity and the alleged losses first had to be examined, verified and quantified under the Act. As no return was filed and no verification was made, the beneficiary's loss claim was set aside and remanded for fresh determination.
Direct assessment of a beneficiary under representative assessee provisions does not dispense with prior determination of the trust's income or loss. The Tribunal found that, where the trust was created by a duly executed instrument, its trustees had to be assessed in that representative capacity and the alleged losses first had to be examined, verified and quantified under the Act. As no return was filed and no verification was made, the beneficiary's loss claim was set aside and remanded for fresh determination.
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