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...
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.
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