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...
GST liability on works or composite supplies remains governed by the applicable statute, whereas reimbursement of an incremental GST burden depends on the contract's allocation of tax risk. An inclusive-tax clause must be read with any change-in-law, price-adjustment, tender or award provisions to determine whether the employer owes an adjustment; GST becoming payable alone does not establish reimbursement. Contract-wise reconciliation of pre- and post-GST work may determine a revised GST-inclusive value and support a supplementary agreement where adjustment is contractually justified. Such contractual relief operates only between contractor and employer and cannot permit revised returns contrary to statute or waive statutory limitation, interest or penalties.
GST liability on works or composite supplies remains governed by the applicable statute, whereas reimbursement of an incremental GST burden depends on the contract's allocation of tax risk. An inclusive-tax clause must be read with any change-in-law, price-adjustment, tender or award provisions to determine whether the employer owes an adjustment; GST becoming payable alone does not establish reimbursement. Contract-wise reconciliation of pre- and post-GST work may determine a revised GST-inclusive value and support a supplementary agreement where adjustment is contractually justified. Such contractual relief operates only between contractor and employer and cannot permit revised returns contrary to statute or waive statutory limitation, interest or penalties.
Note: It is a system-generated summary and is for quick reference only.