Revenue-neutral domestic transfer pricing and mirror transactions justified deletion of related-party adjustments for operation, maintenance and port ...
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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