Approved resolution plans extinguish unsubmitted pre-approval tax claims, preventing later recovery outside the insolvency process and preserving a cl...
Transfer pricing comparability requires functional alignment and permits working capital adjustment, while APA margins cannot govern non-covered years...
Treaty benefit, goodwill depreciation and hedging costs: export commission disallowed, while key business deductions and depreciation claims succeeded...
Event management activity involving planning and organising weddings, exhibitions and similar events was treated as taxable Event Management Service. For valuation, only the commission retained by the appellant could form part of the assessable value; amounts collected merely for payment to third-party vendors were excluded, so the demand on gross receipts failed. Loose papers, uncertified computer printouts and uncorroborated statements were held insufficient to prove clandestine transactions, and the burden remained on the Revenue. The extended period of limitation was wrongly invoked for want of proof of suppression or intent to evade, and the proceedings, including penalties, were set aside as time-barred.
Event management activity involving planning and organising weddings, exhibitions and similar events was treated as taxable Event Management Service. For valuation, only the commission retained by the appellant could form part of the assessable value; amounts collected merely for payment to third-party vendors were excluded, so the demand on gross receipts failed. Loose papers, uncertified computer printouts and uncorroborated statements were held insufficient to prove clandestine transactions, and the burden remained on the Revenue. The extended period of limitation was wrongly invoked for want of proof of suppression or intent to evade, and the proceedings, including penalties, were set aside as time-barred.
Note: It is a system-generated summary and is for quick reference only.