Approved resolution plans extinguish unsubmitted pre-approval tax claims, preventing later recovery outside the insolvency process and preserving a cl...
Transfer pricing comparability requires functional alignment and permits working capital adjustment, while APA margins cannot govern non-covered years...
Treaty benefit, goodwill depreciation and hedging costs: export commission disallowed, while key business deductions and depreciation claims succeeded...
Professional income cannot be assessed by treating an entire doctor's gross receipts as net income solely because no return was filed. For a reasonable assessment, the taxpayer's offer of 50% of receipts as income, tax payment on that basis, and Revenue acceptance of the same approach in subsequent years for the identical profession were relevant, although they did not establish formal eligibility for presumptive taxation under section 44ADA for the relevant year. The Tribunal did not decide whether section 44ADA could be claimed without filing a return. Professional income was restricted to 50% of gross receipts; unpressed grounds were dismissed.
Professional income cannot be assessed by treating an entire doctor's gross receipts as net income solely because no return was filed. For a reasonable assessment, the taxpayer's offer of 50% of receipts as income, tax payment on that basis, and Revenue acceptance of the same approach in subsequent years for the identical profession were relevant, although they did not establish formal eligibility for presumptive taxation under section 44ADA for the relevant year. The Tribunal did not decide whether section 44ADA could be claimed without filing a return. Professional income was restricted to 50% of gross receipts; unpressed grounds were dismissed.
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