International transaction benchmarking restricts transfer pricing adjustments to associated-enterprise dealings, while functional comparability govern...
Joint development agreements defer taxable transfer where possession lacks part performance, while completed flats determine consideration and exempti...
Passenger baggage re-export requires true declaration and cannot be granted indirectly through discretionary redemption of undeclared prohibited goods...
Redemption premium on foreign currency convertible bonds issued to raise and use business funds is characterised as revenue expenditure, because the liability arises on issuance and does not acquire a capital asset or enduring advantage. The notes state that expenditure connected with issuing debentures or obtaining loans is likewise revenue in nature. The premium liability arises in the year of issue and may be proportionately spread over the bonds' prescribed maturity period; it is immaterial whether redemption is at will or only at maturity. The text further records that no substantial question of law arose on either the revenue character or timing of the deduction.
Redemption premium on foreign currency convertible bonds issued to raise and use business funds is characterised as revenue expenditure, because the liability arises on issuance and does not acquire a capital asset or enduring advantage. The notes state that expenditure connected with issuing debentures or obtaining loans is likewise revenue in nature. The premium liability arises in the year of issue and may be proportionately spread over the bonds' prescribed maturity period; it is immaterial whether redemption is at will or only at maturity. The text further records that no substantial question of law arose on either the revenue character or timing of the deduction.
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