Transfer pricing comparables and adjustments: Tribunal revisits loss-maker status, segmental comparability, working capital relief, and risk allocatio...
Business expenditure disallowance failed where commission, related-party salary and promotion payments were supported by records and inquiry was inade...
A Reach Stacker used exclusively for container handling within a restricted Inland Container Depot is described as falling outside the Motor Vehicles Act, 1988 definition of a motor vehicle because it is a special vehicle adapted only for enclosed premises. The text distinguishes road rollers, which are built for road use, and applies the test of whether a vehicle is adapted for use on roads. Restricted depot roads were not a public place because the public had no right of access. The Reach Stacker's specialised design, excess weight, dismantled transportation, lack of ordinary road-safety features and confined utility supported the exclusion. Non-registration alone was not determinative, but followed from its non-motor-vehicle status.
A Reach Stacker used exclusively for container handling within a restricted Inland Container Depot is described as falling outside the Motor Vehicles Act, 1988 definition of a motor vehicle because it is a special vehicle adapted only for enclosed premises. The text distinguishes road rollers, which are built for road use, and applies the test of whether a vehicle is adapted for use on roads. Restricted depot roads were not a public place because the public had no right of access. The Reach Stacker's specialised design, excess weight, dismantled transportation, lack of ordinary road-safety features and confined utility supported the exclusion. Non-registration alone was not determinative, but followed from its non-motor-vehicle status.
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