Embezzlement losses in charitable institutions remain allowable when misappropriation is established, irrecoverable, and not a specified-person benefi...
National long-distance undertaking status supports deduction where separately licensed infrastructure, resources, revenue, and expenditure establish c...
Agency reimbursement income follows contractual deposit-liability computation, while pending deposit collections do not constitute deemed-dividend loa...
Membership-consent thresholds for oppression petitions are satisfied by unchallenged voter-list consents, while unsupported forgery claims require pro...
Advertisement, marketing and promotion (AMP) expenditure did not constitute an international transaction for transfer-pricing purposes, consistent with earlier orders concerning the assessee. Because an arm's length price adjustment presupposes an international transaction, no adjustment could be made for that expenditure. The deletion of the AMP adjustment was sustained, the Revenue's appeals were dismissed, and the assessee's cross-objections became infructuous.
Advertisement, marketing and promotion (AMP) expenditure did not constitute an international transaction for transfer-pricing purposes, consistent with earlier orders concerning the assessee. Because an arm's length price adjustment presupposes an international transaction, no adjustment could be made for that expenditure. The deletion of the AMP adjustment was sustained, the Revenue's appeals were dismissed, and the assessee's cross-objections became infructuous.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4881 
