Transfer-pricing methodology protects commercially genuine associated-enterprise payments, while pre-2016 secondary adjustments and related notional i...
Negative liens over operating assets can constitute international transactions requiring arm's-length pricing reflecting restricted borrowing and expa...
Cross-examination rights in Customs Broker revocation inquiries require witness examination; procedural denial may be cured through fresh adjudication...
Governmental authority status supports construction-service exemption, while pre-cutoff contract and stamp-duty compliance requires verification on re...
Automated Free Sale and Commerce Certificates enable paperless processing while retaining risk-based manual verification for selected exporter applica...
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Denial of claim of loss or to categorize certain expenses as pre-operative expenses - commencement of business during the year - assessee’s business was ‘set up’ or not - The research and development expenses were towards samples of products/ accessories for testing purpose before placing a purchase order and all this are intricate to the nature of business activity of the assessee. - Tax Authorities below fallen in error in concluding that assessee’s business was not ‘set up’ during previous year, to deny the claim of loss or to categorize certain expenses as pre-operative expenses. - AT
Denial of claim of loss or to categorize certain expenses as pre-operative expenses - commencement of business during the year - assessee’s business was ‘set up’ or not - The research and development expenses were towards samples of products/ accessories for testing purpose before placing a purchase order and all this are intricate to the nature of business activity of the assessee. - Tax Authorities below fallen in error in concluding that assessee’s business was not ‘set up’ during previous year, to deny the claim of loss or to categorize certain expenses as pre-operative expenses. - AT
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