Permanent-establishment reassessment cannot revisit scrutinised disclosures; extended reopening fails without undisclosed material facts and within st...
Modified returns after business reorganisation must be assessed within pending proceedings, barring parallel scrutiny and consequential transfer prici...
Turnover mismatches under percentage-completion accounting cannot alone establish suppressed income where customer advances remain recorded as liabili...
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The Tonnage Tax Scheme confines relevant shipping income to profits from specified core and prescribed incidental shipping activities. Receipts from tender-document sales, contractor-delay damages, leased quarters, training fees, other operating income, and salary recoveries from resigned employees fell outside that scope, whereas scrap and empties sales, exchange differences, waste-oil sales, insurance claims, and provision reversals were treated as connected with dredging operations or not separately taxable. Service charges received differing treatment across assessment years in line with earlier determinations. Sponsorship for a maritime investment event qualified as business promotion expenditure because it had a direct business nexus and met commercial expediency, notwithstanding its accounting classification as donation; under the scheme, its debit or disallowance did not affect taxable-profit computation.
The Tonnage Tax Scheme confines relevant shipping income to profits from specified core and prescribed incidental shipping activities. Receipts from tender-document sales, contractor-delay damages, leased quarters, training fees, other operating income, and salary recoveries from resigned employees fell outside that scope, whereas scrap and empties sales, exchange differences, waste-oil sales, insurance claims, and provision reversals were treated as connected with dredging operations or not separately taxable. Service charges received differing treatment across assessment years in line with earlier determinations. Sponsorship for a maritime investment event qualified as business promotion expenditure because it had a direct business nexus and met commercial expediency, notwithstanding its accounting classification as donation; under the scheme, its debit or disallowance did not affect taxable-profit computation.
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