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...
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Reference to a Valuation Officer for a company's fixed assets immediately before expiry of the assessment period was treated as an impermissible attempt to extend the completion deadline. A valuation was unnecessary to examine an alleged bogus depreciation claim because it could be disallowed on the available material. Nor was a genuine valuation required for alleged unaccounted payments: asset-related material and explanations were already on record, later show-cause notices did not question asset valuation, and no satisfactory reason was given for earlier inaction. The reference was characterised as a colourable and illegal use of power to invoke time exclusion, and was quashed.
Reference to a Valuation Officer for a company's fixed assets immediately before expiry of the assessment period was treated as an impermissible attempt to extend the completion deadline. A valuation was unnecessary to examine an alleged bogus depreciation claim because it could be disallowed on the available material. Nor was a genuine valuation required for alleged unaccounted payments: asset-related material and explanations were already on record, later show-cause notices did not question asset valuation, and no satisfactory reason was given for earlier inaction. The reference was characterised as a colourable and illegal use of power to invoke time exclusion, and was quashed.
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