Patent-settlement expenditure treated as commercially expedient revenue outlay, with foreign-law restrictions inapplicable before the prospective amen...
International transaction benchmarking restricts transfer pricing adjustments to associated-enterprise dealings, while functional comparability govern...
Joint development agreements defer taxable transfer where possession lacks part performance, while completed flats determine consideration and exempti...
Depreciation on assets disallowed by authorities due to invoices bearing names of associate company and incorrect dates. Assessee contended ownership transferred via inter-office memos, incorrect invoice dates rectified, assets in use with payments made during assessment year. Business transfer agreement for purchase of running business caused delay in record date of acquisition. No employee cost as operations commenced with directors and assistance from associates, with billing arrangement of cost plus 15% markup to associated enterprise. When revenue accepted based on depreciation plus markup, no reason to deny cost. Authorities erred in disallowing depreciation. Decided in favor of assessee.
Depreciation on assets disallowed by authorities due to invoices bearing names of associate company and incorrect dates. Assessee contended ownership transferred via inter-office memos, incorrect invoice dates rectified, assets in use with payments made during assessment year. Business transfer agreement for purchase of running business caused delay in record date of acquisition. No employee cost as operations commenced with directors and assistance from associates, with billing arrangement of cost plus 15% markup to associated enterprise. When revenue accepted based on depreciation plus markup, no reason to deny cost. Authorities erred in disallowing depreciation. Decided in favor of assessee.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
of 4803
Join Channel
TaxTMI 
