Permanent Establishment and Business Connection: foreign consultancy receipts not attributable where no fixed base or corporate veil piercing establis...
Limitation period commencement and procedural inquiry rules: identity-based limitation upheld; complaints by authorised public servants need not attra...
Claimed royalty for use of a logo was held deductible under the business expenditure test because the assessee produced the agreement and evidence and the payment was established as wholly and exclusively for business, so the royalty addition was deleted. An addition for undervaluation of closing stock was disallowed applying the consistency principle in stock valuation and tax neutrality of corresponding opening stock adjustments, because the assessee consistently excluded freight as in prior years. A capital subsidy granted as an industrial incentive was not required to be reduced from asset cost under the cited cost-reduction exception, so the related addition was deleted.
Claimed royalty for use of a logo was held deductible under the business expenditure test because the assessee produced the agreement and evidence and the payment was established as wholly and exclusively for business, so the royalty addition was deleted. An addition for undervaluation of closing stock was disallowed applying the consistency principle in stock valuation and tax neutrality of corresponding opening stock adjustments, because the assessee consistently excluded freight as in prior years. A capital subsidy granted as an industrial incentive was not required to be reduced from asset cost under the cited cost-reduction exception, so the related addition was deleted.
Note: It is a system-generated summary and is for quick reference only.
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