Tax exemption for regulatory authority income applies retrospectively, subject to non-commercial activity, unchanged income sources, and return filing...
Dispute Resolution Panel objections must reach both prescribed forums; otherwise assessment may proceed and statutory appeal remains the proper remedy...
Political contribution deductions require recipient party compliance with contribution-reporting conditions; banking-channel donations alone do not qu...
Aggregation under TNMM prevents selective testing of intra-group services without comparable uncontrolled transactions, while appellate additional cla...
Protective assessment cannot duplicate identical receipts under competing characterisations; remote services did not establish a taxable permanent est...
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Customs valuation proceedings were maintainable against an STPI unit because section 14 and the valuation rules still governed assessment, even if no duty ultimately arose due to STPI status. The Tribunal held the importer and its parent were related persons throughout the dispute, as wholly owned subsidiary status established mutual interest and, after 2007, direct or indirect control satisfied the related-person test. For the Palladium system imported in 2006, the sale price was accepted because cost certificates showed full cost plus reasonable profit and there was no material to prove price influence. For the other post-2007 goods, loading of the supplier's average profit margin was upheld because the invoices were for customs purposes only and did not reflect arm's-length profit.
Customs valuation proceedings were maintainable against an STPI unit because section 14 and the valuation rules still governed assessment, even if no duty ultimately arose due to STPI status. The Tribunal held the importer and its parent were related persons throughout the dispute, as wholly owned subsidiary status established mutual interest and, after 2007, direct or indirect control satisfied the related-person test. For the Palladium system imported in 2006, the sale price was accepted because cost certificates showed full cost plus reasonable profit and there was no material to prove price influence. For the other post-2007 goods, loading of the supplier's average profit margin was upheld because the invoices were for customs purposes only and did not reflect arm's-length profit.
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