Business reorganisation requires recognition of successor's modified return; draft orders against dissolved transferor quashed and fresh review direct...
Pre-commencement R&D deduction denied where business had not commenced; deeming benefit requires tangible start of manufacture or commercial exploitat...
Priority of set-off: brought forward business losses must be adjusted before unabsorbed depreciation; procedural safeguards required for invoking rest...
Reimbursement of actual staff salary cost from a project office to its head office, with no mark-up, was treated as a payment to self because both formed parts of the same enterprise. On that reasoning, no taxable income arose from the internal allocation, and the amount could not be assessed separately as fees for technical services. The Tribunal followed its earlier view that a transaction between the project office and head office did not generate income in the absence of any element of profit. The addition was deleted for both assessment years.
Reimbursement of actual staff salary cost from a project office to its head office, with no mark-up, was treated as a payment to self because both formed parts of the same enterprise. On that reasoning, no taxable income arose from the internal allocation, and the amount could not be assessed separately as fees for technical services. The Tribunal followed its earlier view that a transaction between the project office and head office did not generate income in the absence of any element of profit. The addition was deleted for both assessment years.
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