Defined public benefit can retain charitable character; registration renewal requires examining genuine activities and legal compliance, not surplus a...
Capital reduction is distinct from share buy-back, preventing buy-back tax; restructuring interest and related business deductions also survive scruti...
Transfer pricing and tax deductions upheld on established principles, while employee contributions and warranty provisions returned for fresh examinat...
Captive transfer pricing relies on industrial consumer tariffs, while genuine quotations can benchmark effluent treatment transfers under the Other Me...
Specific tariff classification for ophthalmic instruments and extended limitation principles determine the treatment of duty demands, confiscation, an...
Integrated golf function determines classification, placing launch monitors and simulators under other golf equipment rather than measuring instrument...
Corporate guarantee furnished to an associated enterprise was treated as a separate international transaction, not a shareholder activity, and the 1% guarantee fee was upheld as arm's length on an internal CUP based on fees charged to other associated enterprises. The bad debt disallowance was deleted because, after the statutory amendment, the assessee need not prove actual irrecoverability once the debt is written off as irrecoverable in the accounts. Lease rentals in a finance lease were also held deductible as revenue expenditure, since book capitalization under AS-19 does not govern tax treatment and depreciation belongs to the legal owner, the lessor.
Corporate guarantee furnished to an associated enterprise was treated as a separate international transaction, not a shareholder activity, and the 1% guarantee fee was upheld as arm's length on an internal CUP based on fees charged to other associated enterprises. The bad debt disallowance was deleted because, after the statutory amendment, the assessee need not prove actual irrecoverability once the debt is written off as irrecoverable in the accounts. Lease rentals in a finance lease were also held deductible as revenue expenditure, since book capitalization under AS-19 does not govern tax treatment and depreciation belongs to the legal owner, the lessor.
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