Defined public benefit can retain charitable character; registration renewal requires examining genuine activities and legal compliance, not surplus a...
Capital reduction is distinct from share buy-back, preventing buy-back tax; restructuring interest and related business deductions also survive scruti...
Transfer pricing and tax deductions upheld on established principles, while employee contributions and warranty provisions returned for fresh examinat...
Captive transfer pricing relies on industrial consumer tariffs, while genuine quotations can benchmark effluent treatment transfers under the Other Me...
Valuation - inclusion of advertisement and publicity expenses incurred by the dealers as per the terms and conditions of the dealership agreement mutually agreed between the appellant and their dealers, in the assessable value of the vehicles sold by the appellant - The Tribunal found that the dealership agreement did not impose an enforceable right on the appellant to require dealers to incur specific advertisement expenses. It concluded that since the expenses were incurred at the dealers' discretion and the sale price of vehicles to dealers was unaffected by whether dealers chose to advertise, such expenses should not be included in the assessable value.
Valuation - inclusion of advertisement and publicity expenses incurred by the dealers as per the terms and conditions of the dealership agreement mutually agreed between the appellant and their dealers, in the assessable value of the vehicles sold by the appellant - The Tribunal found that the dealership agreement did not impose an enforceable right on the appellant to require dealers to incur specific advertisement expenses. It concluded that since the expenses were incurred at the dealers' discretion and the sale price of vehicles to dealers was unaffected by whether dealers chose to advertise, such expenses should not be included in the assessable value.
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