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...
Notional usage charges for premises occupied by a sister concern were not taxable as income from other sources because no evidence showed that such charges were received or had become receivable; reimbursement of expenses alone had been implemented. Related repairs, maintenance, service charges and depreciation were deductible where incurred wholly and exclusively to earn that income, while building-related expenses and depreciation had to be restricted to the area let to a third-party tenant and assessable as house-property income. Trade incentives for brand promotion were treated as revenue expenditure, removing the ad hoc disallowance. Depreciation was allowable on moulds and dies because their use in manufacturing plastic containers established that they had been put to use.
Notional usage charges for premises occupied by a sister concern were not taxable as income from other sources because no evidence showed that such charges were received or had become receivable; reimbursement of expenses alone had been implemented. Related repairs, maintenance, service charges and depreciation were deductible where incurred wholly and exclusively to earn that income, while building-related expenses and depreciation had to be restricted to the area let to a third-party tenant and assessable as house-property income. Trade incentives for brand promotion were treated as revenue expenditure, removing the ad hoc disallowance. Depreciation was allowable on moulds and dies because their use in manufacturing plastic containers established that they had been put to use.
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