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...
Service of notice and opportunity of hearing were treated as adequate where the director knew of the investigation, sought time to respond, then neither replied nor updated the address despite repeated service attempts. No breach of natural justice arose from non-cooperation. Non-realisation of export proceeds triggered a statutory presumption that reasonable recovery steps had not been taken. As the director was in charge during the contravention and did not establish realisation or efforts to obtain information from the Official Liquidator, company liquidation did not remove liability. The penalty was sustained but confined to the amount already deposited, considering the elapsed period and liquidation.
Service of notice and opportunity of hearing were treated as adequate where the director knew of the investigation, sought time to respond, then neither replied nor updated the address despite repeated service attempts. No breach of natural justice arose from non-cooperation. Non-realisation of export proceeds triggered a statutory presumption that reasonable recovery steps had not been taken. As the director was in charge during the contravention and did not establish realisation or efforts to obtain information from the Official Liquidator, company liquidation did not remove liability. The penalty was sustained but confined to the amount already deposited, considering the elapsed period and liquidation.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4891 
