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...
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.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
of 4782
Join Channel
TaxTMI 
