Higher depreciation for qualifying commercial vehicles, exempt-income disallowance, research deduction verification, and club-expense treatment clarif...
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...
Sections 92A(1) and 92A(2) require a harmonious reading: the statutory circumstances in section 92A(2), including business dependence under section 92A(2)(g), do not independently establish an associated-enterprise relationship without participation in management, control or capital under section 92A(1). Commercial dependence or distribution exclusivity alone is insufficient absent evidence of ownership, voting rights, managerial participation or financial control. For internal CUP analysis, contractual differences do not disqualify an uncontrolled transaction unless they materially affect the royalty rate and cannot be eliminated through reasonably accurate, objectively verifiable adjustments. Royalty benchmarking was remanded to examine those differences and adjustments; if CUP is unreliable, the most appropriate method must be independently selected.
Sections 92A(1) and 92A(2) require a harmonious reading: the statutory circumstances in section 92A(2), including business dependence under section 92A(2)(g), do not independently establish an associated-enterprise relationship without participation in management, control or capital under section 92A(1). Commercial dependence or distribution exclusivity alone is insufficient absent evidence of ownership, voting rights, managerial participation or financial control. For internal CUP analysis, contractual differences do not disqualify an uncontrolled transaction unless they materially affect the royalty rate and cannot be eliminated through reasonably accurate, objectively verifiable adjustments. Royalty benchmarking was remanded to examine those differences and adjustments; if CUP is unreliable, the most appropriate method must be independently selected.
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