Transfer pricing comparables and adjustments: Tribunal revisits loss-maker status, segmental comparability, working capital relief, and risk allocatio...
Business expenditure disallowance failed where commission, related-party salary and promotion payments were supported by records and inquiry was inade...
Subscriptions from members form corpus or common fund and, under the principle of mutuality, are not taxable; interest earned on bank deposits is prima facie taxable but may be appropriated to meet bona fide payments to members. The document recognises a right of appropriation whereby the society may first apply taxable interest receipts to discharge death claims, pensions, voluntary retirement and retirement benefits for members, and only thereafter draw on subscriptions if required. The operative effect directs reassessment to allow set off of such member payments against taxable receipts when determining tax liability.
Subscriptions from members form corpus or common fund and, under the principle of mutuality, are not taxable; interest earned on bank deposits is prima facie taxable but may be appropriated to meet bona fide payments to members. The document recognises a right of appropriation whereby the society may first apply taxable interest receipts to discharge death claims, pensions, voluntary retirement and retirement benefits for members, and only thereafter draw on subscriptions if required. The operative effect directs reassessment to allow set off of such member payments against taxable receipts when determining tax liability.
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