Transfer pricing comparability requires functional alignment, reliable financial data, and careful review of working capital and receivables adjustmen...
Transfer pricing rules require benchmarking corporate guarantees and associated-enterprise advances, while invalid domestic-transaction adjustments ca...
Prospective sugar export prohibition required registered letters of credit; private contracts and export quotas created no enforceable continuation ri...
Retroactive interim-moratorium exclusion permits protective asset disclosure and preservation measures against personal guarantors pending arbitration...
Depreciation on vehicles under operating leases is discussed in relation to ownership where registration certificates stand in customers' names. Master Lease Agreements may establish the lessor's ownership and customers' limited right of use; registration and lessee use do not, by themselves, displace depreciation eligibility. The text also addresses an undecided ground concerning deferred maintenance charges, noting that where a specifically raised ground has not been determined, it requires limited fresh consideration. It describes depreciation questions as not raising a substantial question of law and the maintenance-charge issue as remanded for determination.
Depreciation on vehicles under operating leases is discussed in relation to ownership where registration certificates stand in customers' names. Master Lease Agreements may establish the lessor's ownership and customers' limited right of use; registration and lessee use do not, by themselves, displace depreciation eligibility. The text also addresses an undecided ground concerning deferred maintenance charges, noting that where a specifically raised ground has not been determined, it requires limited fresh consideration. It describes depreciation questions as not raising a substantial question of law and the maintenance-charge issue as remanded for determination.
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