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...
Commodity-trading receivables written off as bad debts qualify for deduction where they were previously included in income and written off in the books; a possible future recovery does not justify disallowance. Characterising the transactions as speculative or the amount as capital investment does not displace fulfilment of those conditions. The bad-debt disallowance was deleted, subject to taxation of any later recovery in the year received. For windmill-profit deductions, head-office expenses and depreciation on common assets require factual examination of their components, use and allocation to eligible operations. That computation was remanded for fresh adjudication.
Commodity-trading receivables written off as bad debts qualify for deduction where they were previously included in income and written off in the books; a possible future recovery does not justify disallowance. Characterising the transactions as speculative or the amount as capital investment does not displace fulfilment of those conditions. The bad-debt disallowance was deleted, subject to taxation of any later recovery in the year received. For windmill-profit deductions, head-office expenses and depreciation on common assets require factual examination of their components, use and allocation to eligible operations. That computation was remanded for fresh adjudication.
Note: It is a system-generated summary and is for quick reference only.
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