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...
Rule 68B's amended recovery period applies only where the original limitation period remained alive when the amendment took effect; recovery for 2007-08 and 2008-09 was therefore barred, while proceedings for 2009-10 to 2011-12 remained timely. Service on the defaulting firm sufficed for sale of its assets, particularly where partners received copies and participated; individual notice is required where recovery targets a partner's personal assets. Auction valuation was not defective because sale prices exceeded guideline and partner-declared market values, and revised reserve prices alone showed no undervaluation. Third-party funding of demand drafts did not invalidate compliant auction payments. The recovery auction was confirmed and the sale certificate was to issue to the purchaser.
Rule 68B's amended recovery period applies only where the original limitation period remained alive when the amendment took effect; recovery for 2007-08 and 2008-09 was therefore barred, while proceedings for 2009-10 to 2011-12 remained timely. Service on the defaulting firm sufficed for sale of its assets, particularly where partners received copies and participated; individual notice is required where recovery targets a partner's personal assets. Auction valuation was not defective because sale prices exceeded guideline and partner-declared market values, and revised reserve prices alone showed no undervaluation. Third-party funding of demand drafts did not invalidate compliant auction payments. The recovery auction was confirmed and the sale certificate was to issue to the purchaser.
Note: It is a system-generated summary and is for quick reference only.