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...
TP Adjustment - comparable selection - The issues included the rejection of the CUP method, selection of comparable companies, and rejection of a foreign Associated Enterprise as the tested party. The Tribunal upheld the transfer pricing adjustment but directed the exclusion of one comparable and the inclusion of another based on the arguments presented.
TP Adjustment - comparable selection - The issues included the rejection of the CUP method, selection of comparable companies, and rejection of a foreign Associated Enterprise as the tested party. The Tribunal upheld the transfer pricing adjustment but directed the exclusion of one comparable and the inclusion of another based on the arguments presented.
Note: It is a system-generated summary and is for quick reference only.