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...
Under the mercantile system of accounting, notional interest on outstanding advances was not justified where evidence showed that no interest had been received for two preceding years and the debtor concerns' financial condition had deteriorated. One concern had ceased business activity, as indicated by cancellation of its sales tax registration and application to cancel excise registration, while material concerning the other concern was not properly considered. Family relationships with the assessee's partners alone did not support imputing interest. The article records that the High Court treated the contrary findings as perverse and deleted the notional-interest addition.
Under the mercantile system of accounting, notional interest on outstanding advances was not justified where evidence showed that no interest had been received for two preceding years and the debtor concerns' financial condition had deteriorated. One concern had ceased business activity, as indicated by cancellation of its sales tax registration and application to cancel excise registration, while material concerning the other concern was not properly considered. Family relationships with the assessee's partners alone did not support imputing interest. The article records that the High Court treated the contrary findings as perverse and deleted the notional-interest addition.
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