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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Leasehold transfers of land to approved Special Economic Zone units qualify as transfers of land for stamp duty and registration fee exemptions intended to promote industrial establishment. A lease conveys a transferable interest in land for the stipulated term and is not confined to an outright sale. Promissory estoppel protects SEZ fiscal incentives promised under State policy where a lease was executed before the implementing Ordinance, because the Ordinance gave statutory effect to the existing policy. Denial based solely on the timing of the Ordinance would defeat the governmental promise and create unequal treatment of similarly situated SEZ units. The exemption consequently extends to the leasehold transfer, requiring refund processing.
Leasehold transfers of land to approved Special Economic Zone units qualify as transfers of land for stamp duty and registration fee exemptions intended to promote industrial establishment. A lease conveys a transferable interest in land for the stipulated term and is not confined to an outright sale. Promissory estoppel protects SEZ fiscal incentives promised under State policy where a lease was executed before the implementing Ordinance, because the Ordinance gave statutory effect to the existing policy. Denial based solely on the timing of the Ordinance would defeat the governmental promise and create unequal treatment of similarly situated SEZ units. The exemption consequently extends to the leasehold transfer, requiring refund processing.
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