Enforcement of resolution-plan directions continues without a Supreme Court stay, preventing suspension of redistribution and escrowed-fund distributi...
Third-party ownership claims over attached property require Special Court adjudication where purchasers lack registered sale deeds and bona fides rema...
Pure-agent reimbursements in clearing and forwarding services are excluded from taxable value when qualifying third-party payments are properly record...
Customs relief for Strait of Hormuz maritime disruptions remains available, with existing conditions continuing unchanged through the extended validit...
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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