Approved resolution plans extinguish unsubmitted pre-approval tax claims, preventing later recovery outside the insolvency process and preserving a cl...
Transfer pricing comparability requires functional alignment and permits working capital adjustment, while APA margins cannot govern non-covered years...
Treaty benefit, goodwill depreciation and hedging costs: export commission disallowed, while key business deductions and depreciation claims succeeded...
Unsupported claims for expenditure against commission income cannot be accepted solely on the taxpayer's assertions. The text explains that, despite the absence of documentary evidence, the nature of commission activities, the taxpayer's age, cash withdrawals and the scale of commission receipts indicated that substantial expenditure on assistance, administrative needs and incidental items was inevitable. It considers an estimate of 10 per cent of gross commission receipts inadequate and prescribes allowance of expenditure at 20 per cent, requiring consequential recomputation of income.
Unsupported claims for expenditure against commission income cannot be accepted solely on the taxpayer's assertions. The text explains that, despite the absence of documentary evidence, the nature of commission activities, the taxpayer's age, cash withdrawals and the scale of commission receipts indicated that substantial expenditure on assistance, administrative needs and incidental items was inevitable. It considers an estimate of 10 per cent of gross commission receipts inadequate and prescribes allowance of expenditure at 20 per cent, requiring consequential recomputation of income.
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