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...
Integrated golf function determines classification, placing launch monitors and simulators under other golf equipment rather than measuring instrument...
Public servant status under anti-corruption law extends to recognised stock exchange leadership; constitutional and sanction challenges do not succeed...
Acquiescence, homebuyer protection and clean-slate resolution principles prevent landowners from disrupting an integrated project through late termina...
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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