International transaction characterisation of domestic divestment of support services business rejected; transaction between resident associated enter...
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Transaction value between related persons requires market-equivalent pricing; importer must prove declared value mirrors ordinary international trade ...
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Assessments concern timing and allowability of various business...
Time Relevance of Expense: commission deductible when incurred; restructuring transfers, lease obligations upheld; unenforceable sale agreement bars loss claim.
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Assessments concern timing and allowability of various business deductions. Commission paid to secure a tenant was held to be a genuine, time relevant business expense deductible when incurred rather than deferred to rent receipt. Interest on continued loans was accepted due to prior recognition and use of interest free funds. Transfer of non current investments to a group holding was treated as business expediency for corporate consolidation and not disturbed. Housekeeping and security costs payable under the lease were deductible as operational obligations. Claimed capital loss carry forward was disallowed where sale agreements were not acted upon and lacked enforceable documentation.
Assessments concern timing and allowability of various business deductions. Commission paid to secure a tenant was held to be a genuine, time relevant business expense deductible when incurred rather than deferred to rent receipt. Interest on continued loans was accepted due to prior recognition and use of interest free funds. Transfer of non current investments to a group holding was treated as business expediency for corporate consolidation and not disturbed. Housekeeping and security costs payable under the lease were deductible as operational obligations. Claimed capital loss carry forward was disallowed where sale agreements were not acted upon and lacked enforceable documentation.
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