Market value for captive electricity consumption follows industrial consumer tariffs, supporting profit computation for the power generation deduction...
Provisional release of seized imports requires enhanced duty payment, bank guarantee and disclosures while customs adjudication proceeds independently...
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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