Bogus donation receipts justified commission income assessment and defeated political-party tax exemption for inaccurate accounts and reporting failur...
Pure reimbursement without income element escapes tax withholding, while delayed withholding and unsupported provisions face deferred or renewed scrut...
Public benefit requirement defeats charitable registration where residents' association services are reciprocal, member-only facilities governed by mu...
Exempt-income expenditure disallowance is confined to investments that actually generated exempt income, while supported business expenses remain dedu...
TP adjustment - application of the Resale Price Method (RPM) as the Most Appropriate Method (‘MAM’) - trading activity - The decision of Supreme Court in Kedarnath Jute Manufacturing Co. Ltd.[1965 (4) TMI 91 - SUPREME COURT] is an authority for the proposition that tax authorities and adjudications as well as assessee are not precluded by the positions taken in returns, documents or accounts and have the duty (and a corresponding right) to apply the correct legal principle. Thus, the use of one method in a transfer pricing report does not estop the assessee from later claiming that another method is the most appropriate one, provided that is indeed the correct position. - HC
TP adjustment - application of the Resale Price Method (RPM) as the Most Appropriate Method (‘MAM’) - trading activity - The decision of Supreme Court in Kedarnath Jute Manufacturing Co. Ltd.[1965 (4) TMI 91 - SUPREME COURT] is an authority for the proposition that tax authorities and adjudications as well as assessee are not precluded by the positions taken in returns, documents or accounts and have the duty (and a corresponding right) to apply the correct legal principle. Thus, the use of one method in a transfer pricing report does not estop the assessee from later claiming that another method is the most appropriate one, provided that is indeed the correct position. - HC
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4809 
Join Channel 
