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Transfer-pricing benchmarking and capital-receipt principles sustained taxpayer relief, while unsupported property-advance write-offs remained disallo...
Pre-existing operational debt disputes require genuine evidence, while undirected running-account payments may be appropriated on a first-in-first-out...
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For share-premium taxation of unquoted shares, a chartered accountant's valuation report supported by detailed workings may not be rejected merely on suspicion or without examining its underlying material. The notes state that an Assessing Officer's independent net asset value calculation was not sustainable where the officer lacked valuation expertise and had not addressed the submitted report, resulting in deletion of the excess share-premium addition. They also explain that, in a limited-scrutiny assessment restricted to advances, loans and share premium, expenditure disallowance falls outside jurisdiction unless recorded satisfaction and prior approval permit conversion to complete scrutiny. The expenditure disallowance was therefore deleted, and the Revenue's appeal was dismissed.
For share-premium taxation of unquoted shares, a chartered accountant's valuation report supported by detailed workings may not be rejected merely on suspicion or without examining its underlying material. The notes state that an Assessing Officer's independent net asset value calculation was not sustainable where the officer lacked valuation expertise and had not addressed the submitted report, resulting in deletion of the excess share-premium addition. They also explain that, in a limited-scrutiny assessment restricted to advances, loans and share premium, expenditure disallowance falls outside jurisdiction unless recorded satisfaction and prior approval permit conversion to complete scrutiny. The expenditure disallowance was therefore deleted, and the Revenue's appeal was dismissed.
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