Working-capital adjustment determines whether software-services transfer-pricing margins fall within the statutory tolerance range, eliminating any ad...
Permanent establishment deductions upheld for expatriate salaries, direct costs and trading losses, while head-office costs require fresh classificati...
Data transmission equipment classification under CTSH 8517 62 remains distinct from residual classification, with exemption evidence requiring scrutin...
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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