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...
Upper turnover filters in transfer-pricing comparable selection may be applied where differences in turnover, brand value, economies of scale, bargaining power and ownership of intangibles materially affect profitability and comparability. High-turnover software-development companies were treated as unsuitable comparables because their scale and functional profile differed from that of the tested party. The approach supports excluding enterprises exceeding the stated turnover threshold when scale-related factors distort an arm's-length comparison.
Upper turnover filters in transfer-pricing comparable selection may be applied where differences in turnover, brand value, economies of scale, bargaining power and ownership of intangibles materially affect profitability and comparability. High-turnover software-development companies were treated as unsuitable comparables because their scale and functional profile differed from that of the tested party. The approach supports excluding enterprises exceeding the stated turnover threshold when scale-related factors distort an arm's-length comparison.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4881 
