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...
Website development costs are discussed as qualifying for depreciation at the higher rate applied to computer software, based on earlier decisions. Payment gateway charges paid to banks are characterised as banking-service fees rather than commission or brokerage because the gateway facilitates secure payment settlement without acting as an agent; consequently, tax deduction obligations on commission were not attracted. Advertisement, marketing and publicity expenditure is treated as revenue expenditure where it forms part of the profit-earning process and creates no permanent asset or enduring advantage of decisive character. Ticket-cost reimbursements to an overseas group company are also discussed as not being expenditure claimed by the assessee, supporting deletion of the related tax-deduction disallowance.
Website development costs are discussed as qualifying for depreciation at the higher rate applied to computer software, based on earlier decisions. Payment gateway charges paid to banks are characterised as banking-service fees rather than commission or brokerage because the gateway facilitates secure payment settlement without acting as an agent; consequently, tax deduction obligations on commission were not attracted. Advertisement, marketing and publicity expenditure is treated as revenue expenditure where it forms part of the profit-earning process and creates no permanent asset or enduring advantage of decisive character. Ticket-cost reimbursements to an overseas group company are also discussed as not being expenditure claimed by the assessee, supporting deletion of the related tax-deduction disallowance.
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