Working-capital adjustment determines whether software-services transfer-pricing margins fall within the statutory tolerance range, eliminating any ad...
Permanent establishment deductions upheld for expatriate salaries, direct costs and trading losses, while head-office costs require fresh classificati...
Data transmission equipment classification under CTSH 8517 62 remains distinct from residual classification, with exemption evidence requiring scrutin...
Protective assessment of seized jewellery requires independent evidence that the person in physical possession is its actual or beneficial owner where the same jewellery has been substantively assessed in the hands of a company claiming ownership. Physical possession and inability to prove another person's ownership do not displace the Revenue's substantive treatment when the individual consistently denies ownership and no positive material establishes ownership. Failure to pursue a first appeal does not cure the absence of evidence or transform a protective addition into a substantive charge. The protective addition for unexplained jewellery was deleted, and consequential interest was to be recomputed.
Protective assessment of seized jewellery requires independent evidence that the person in physical possession is its actual or beneficial owner where the same jewellery has been substantively assessed in the hands of a company claiming ownership. Physical possession and inability to prove another person's ownership do not displace the Revenue's substantive treatment when the individual consistently denies ownership and no positive material establishes ownership. Failure to pursue a first appeal does not cure the absence of evidence or transform a protective addition into a substantive charge. The protective addition for unexplained jewellery was deleted, and consequential interest was to be recomputed.
Note: It is a system-generated summary and is for quick reference only.
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