Charitable registration renewal cannot become an assessment of receipts, profitability or annual exemption compliance, requiring renewal and donation ...
AMP expenditure for own business is not an international transaction without an associated-enterprise arrangement, eliminating transfer pricing adjust...
Customs valuation must use comparable contemporary imports, while confiscation fines and penalties require proportionate recalculation on reassessed v...
Depositor-protection proceedings prevail over corporate insolvency, while liquidators may recover chit receivables using copies of seized company reco...
Transfer pricing rules require benchmarking the actual international transaction and generally prohibit re-characterising legally valid compulsorily convertible debentures as equity merely because another commercial structure appears preferable. Compulsory conversion, lack of repayment before conversion, and separate regulatory or accounting treatment do not alter their debt character until conversion. The nil arm's length price for interest was therefore set aside, with fresh benchmarking required using CUP or another permissible method. Bad debts written off are deductible where statutory conditions are met and debtor accounts are correspondingly extinguished; independent proof of irrecoverability is unnecessary. The bad-debt disallowance was deleted.
Transfer pricing rules require benchmarking the actual international transaction and generally prohibit re-characterising legally valid compulsorily convertible debentures as equity merely because another commercial structure appears preferable. Compulsory conversion, lack of repayment before conversion, and separate regulatory or accounting treatment do not alter their debt character until conversion. The nil arm's length price for interest was therefore set aside, with fresh benchmarking required using CUP or another permissible method. Bad debts written off are deductible where statutory conditions are met and debtor accounts are correspondingly extinguished; independent proof of irrecoverability is unnecessary. The bad-debt disallowance was deleted.
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