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 29 compliance for additional evidence required fresh examination where an affidavit accompanying Paper Book No. II-A expressly sought permission and the materials were prima facie available in the Tribunal's records. The dismissal of the related rectification application was partly set aside and remitted for determining whether the paper book had been properly filed under Rule 29, whether its contents were relevant to the appeal, and any consequential relief. Findings concerning the other paper book and remaining grounds remained undisturbed.
Rule 29 compliance for additional evidence required fresh examination where an affidavit accompanying Paper Book No. II-A expressly sought permission and the materials were prima facie available in the Tribunal's records. The dismissal of the related rectification application was partly set aside and remitted for determining whether the paper book had been properly filed under Rule 29, whether its contents were relevant to the appeal, and any consequential relief. Findings concerning the other paper book and remaining grounds remained undisturbed.
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TaxTMI 
TaxTMI 
of 4883 
