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...
Delayed trade receivables from an associated enterprise that remain unpaid beyond the agreed credit period are treated as a separate financing transaction and require independent arm's length benchmarking. Only the delay exceeding the actual arm's length credit period should attract interest, calculated in the receivable currency with a justified spread; LIBOR plus 200 basis points is prescribed for foreign-currency receivables. For ITES comparable selection, verification is required of the service-income and 25% related-party transaction filters. The turnover filter excludes companies with turnover above ten times or below one-tenth of the tested party's turnover.
Delayed trade receivables from an associated enterprise that remain unpaid beyond the agreed credit period are treated as a separate financing transaction and require independent arm's length benchmarking. Only the delay exceeding the actual arm's length credit period should attract interest, calculated in the receivable currency with a justified spread; LIBOR plus 200 basis points is prescribed for foreign-currency receivables. For ITES comparable selection, verification is required of the service-income and 25% related-party transaction filters. The turnover filter excludes companies with turnover above ten times or below one-tenth of the tested party's turnover.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4888 
