Defined public benefit can retain charitable character; registration renewal requires examining genuine activities and legal compliance, not surplus a...
Capital reduction is distinct from share buy-back, preventing buy-back tax; restructuring interest and related business deductions also survive scruti...
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...
Transfer-pricing comparability requires functional similarity and reliable current-year segmental data. Bilcare Ltd. was excluded because of diversified operations, unavailable segmental data, and its pharmaceutical packaging profile, which differed from paper-based aseptic packaging for food and drink products. Karur KCP Packaging Ltd. was excluded because it produced kraft paper and polypropylene bags principally for the cement industry, making its products materially dissimilar. Earlier-year segmental data could not support current-year inclusion where relevant data was unavailable. The Tribunal's fact-based comparability findings disclosed neither error nor perversity, so no substantial question of law arose and the Revenue's appeal was dismissed; the separate Revenue appeal issue remained open.
Transfer-pricing comparability requires functional similarity and reliable current-year segmental data. Bilcare Ltd. was excluded because of diversified operations, unavailable segmental data, and its pharmaceutical packaging profile, which differed from paper-based aseptic packaging for food and drink products. Karur KCP Packaging Ltd. was excluded because it produced kraft paper and polypropylene bags principally for the cement industry, making its products materially dissimilar. Earlier-year segmental data could not support current-year inclusion where relevant data was unavailable. The Tribunal's fact-based comparability findings disclosed neither error nor perversity, so no substantial question of law arose and the Revenue's appeal was dismissed; the separate Revenue appeal issue remained open.
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