Charitable sports promotion: sponsorship receipts alone did not defeat registration where funds supported tournaments and player development activitie...
Overdue associated-enterprise receivables: debt-free status defeated notional-interest adjustment, while employee stock-option costs qualified as busi...
Retrospective assessment-limitation amendments validate final orders while contemporaneous segment data governs transfer-pricing comparability and tol...
Transfer pricing adjustments must track international transactions, while unsupported AMP adjustments and unsuitable manufacturing comparables require...
Transfer-pricing adjustments must reflect functional comparability, working-capital effects, and avoid duplicating interest on associated-enterprise r...
Corporate guarantee liability becomes deductible in the previous year in which settlement fixes and crystallises the obligation. Where the settlement occurred in the previous year relevant to Assessment Year 1998-99, subsequent consent terms merely implemented and discharged the already determined liability; they did not defer the year of deduction. The resulting business-loss deduction was therefore allowable for Assessment Year 1998-99.
Corporate guarantee liability becomes deductible in the previous year in which settlement fixes and crystallises the obligation. Where the settlement occurred in the previous year relevant to Assessment Year 1998-99, subsequent consent terms merely implemented and discharged the already determined liability; they did not defer the year of deduction. The resulting business-loss deduction was therefore allowable for Assessment Year 1998-99.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4891 
