Transfer pricing and tax deductions upheld on established principles, while employee contributions and warranty provisions returned for fresh examinat...
Captive transfer pricing relies on industrial consumer tariffs, while genuine quotations can benchmark effluent treatment transfers under the Other Me...
Specific tariff classification for ophthalmic instruments and extended limitation principles determine the treatment of duty demands, confiscation, an...
Integrated golf function determines classification, placing launch monitors and simulators under other golf equipment rather than measuring instrument...
Public servant status under anti-corruption law extends to recognised stock exchange leadership; constitutional and sanction challenges do not succeed...
Acquiescence, homebuyer protection and clean-slate resolution principles prevent landowners from disrupting an integrated project through late termina...
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For Section 44B, "carriage" of passengers by a foreign shipping enterprise extends beyond transportation between two ports. A round cruise voyage may remain passenger carriage where passengers can disembark at intermediate ports and the principal receipts arise from cabin and transport fares. On-board hospitality and entertainment are ancillary to the voyage and do not, by themselves, remove cruise operations from the presumptive taxation scheme. The text states that the non-resident cruise operator's income was therefore computable under Section 44B at the prescribed presumptive rate, and the concurrent finding treating the activity as passenger carriage was affirmed.
For Section 44B, "carriage" of passengers by a foreign shipping enterprise extends beyond transportation between two ports. A round cruise voyage may remain passenger carriage where passengers can disembark at intermediate ports and the principal receipts arise from cabin and transport fares. On-board hospitality and entertainment are ancillary to the voyage and do not, by themselves, remove cruise operations from the presumptive taxation scheme. The text states that the non-resident cruise operator's income was therefore computable under Section 44B at the prescribed presumptive rate, and the concurrent finding treating the activity as passenger carriage was affirmed.
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